I'm reviewing a loan and need some advice on how to report for HMDA. The loan is a HELOC where the borrower is using the funds to construct a detached outbuilding on his primary residence. The outbuilding is being constructed for an office to house his business, personal RV/vehicle storage, and a living space to be used as a rental. Based on the information provided in the file and lender, the Sq feet of the outbuilding is not detailed; however, I was able to find that the borrower's business generates more income than the proposed rental. At this time I would not consider this outbuilding as a dwelling.
My questions are:
- Would the transaction be considered "commercial" or "consumer"?
- Would the purpose of funds be "home improvement" or "other"?
Thank in advance!