I have a loan to a developer where 4 residential properties are the collateral. 3 of the properties will be sold and the 4th property is the guarantor's primary resident. The purpose of the funds were for construction cost overruns on the 3 residential properties that are being sold.

I was originally thinking that loan would not be HMDA reportable under temporary financing, because the loan is a construction loan to developer to build and sell. I am hung up on the fact that we also took the guarantor's primary residence as additional collateral due to LTV/CLTV ratios.

Please advise if is HMDA as Home Improvement or not HMDA reportable.

The presence of an additional piece of collateral in the form of the builder's primary residence doesn't change the exemption.....still exempt and not reportable.