We have a commercial loan to an individual that is HMDA reportable. It's secured by multiple properties most of them are single family homes, but one is a 25 unit apartment. We only report one of the properties on loans secured by multiple properties. The property we are reporting for HMDA is one of the single family homes. Do we report income since the loan is secured by a multi-family dwelling even though it isn't the one we are reporting in the LAR? The loan officer thinks it should be reported as NA, our person responsible for HMDA thinks the income should be reported, and I'm not sure.

8. Income data—multifamily properties. A financial institution complies with § 1003.4(a)(10)(iii)
by reporting that the requirement is not applicable when the covered loan is secured by, or
application is proposed to be secured by, a multifamily dwelling.


I would vote NA.