We have a loan to refi a multifamily dwelling. Our customer leases the property to a community organization that provides transitional housing services for homeless veterans through the VA's grant and per diem program.

Does this program qualify as "income-restricted pursuant to Federal, State, or local affordable housing programs" and require us to report the units as affordable multifamily units for HMDA?

Would this not fall under a transitory residence?

Properties with service and medical components. For purposes of § 1003.2(f), a property
used for both long-term housing and to provide related services, such as assisted living for
senior citizens or supportive housing for persons with disabilities, is a dwelling and does not
have a non-residential purpose merely because the property is used for both housing and to
provide services. However, transitory residences that are used to provide such services are not
dwellings. See comment 2(f)-3. Properties that are used to provide medical care, such as skilled
nursing, rehabilitation, or long-term medical care, also are not dwellings. See comment 2(f)-3. If
a property that is used for both long-term housing and to provide related services also is used to
provide medical care, the property is a dwelling if its primary use is residential. An institution
may use any reasonable standard to determine the property's primary use, such as by square
footage, income generated, or number of beds or units allocated for each use. An institution
may select the standard to apply on a case-by-case basis.

I thought about that, but the veteran can utilize the program for up to two years, so I'm reluctant to call it transitory.