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#2261003 - 10/11/21 10:00 PM Been Out of HMDA for Years -Simple Question
Tesla Offline
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OK - I have not been involved with HMDA in probably close to 10 years. I have read the HMDA Getting It Right Guide and the changes to Reg C, but just want to make sure I have one thing clear - purpose no longer matters, right? I mean you have to report the purpose on a covered loan, but for determining if a loan is reportable or not, all you look at is if the loan is open or closed end credit and secured by a dwelling (and not covered under an exemption). Is that right????
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#2261033 - 10/12/21 07:01 PM Re: Been Out of HMDA for Years -Simple Question Tesla
CloudShape Offline
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Yes and no. There does have to be a dwelling securing the loan in order to be HMDA, but if you are looking at a dwelling secured commercial loan, it still has to be purchase, HI, or refinance to be HMDA. There is no 'Other' for commercial loans as there is for consumer.

Also, watch out for what is a 'dwelling' under the new rules. A mobile home park is a dwelling for HMDA even if there are no mobile homes. And a mobile home constructed before June 15 (?), 1976 is not a dwelling (not sure of the exact date off the top of my head). There are a few odd quirks like that in the new rule.
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#2261037 - 10/12/21 07:34 PM Re: Been Out of HMDA for Years -Simple Question Tesla
Tesla Offline
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Oh geez! Thank you! Not sure how I missed that detail!
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#2261057 - 10/13/21 12:14 PM Re: Been Out of HMDA for Years -Simple Question Tesla
Adam Witmer Offline
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Tesla, if you have been out of HMDA for ten years, take a look at this flow chart that can more quickly help you determine HMDA applicability of a loan under the current rules. https://files.consumerfinance.gov/f/documents/cfpb_2022-hmda-transactional-coverage.pdf

And good luck getting back into HMDA! wink
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#2261059 - 10/13/21 01:17 PM Re: Been Out of HMDA for Years -Simple Question Tesla
Tesla Offline
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That is exactly what I needed Adam- thank you!!!
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#2261893 - 11/01/21 03:15 PM Re: Been Out of HMDA for Years -Simple Question Tesla
HMDA CRA Gal Offline
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Posts: 37
Would a mobile home park constructed before June 1976 be HMDA reportable. I know that mobile homes constructed before then are not reportable. Would this apply to the community or park with just sites for the mobile homes?

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#2261896 - 11/01/21 03:44 PM Re: Been Out of HMDA for Years -Simple Question Tesla
rlcarey Offline
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Galveston, TX
Just the mobile homes.
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#2261898 - 11/01/21 03:52 PM Re: Been Out of HMDA for Years -Simple Question Tesla
HMDA CRA Gal Offline
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So we have a loan to purchase a property that consists of a residential dwelling and 19 mobile home pads. How would we report Construction Method, Manufactured Home Secured Property Type and Manufactured Home Property Interest. If it were just the manufacture home community, we would report these data points as 2-Manufactured Home, 3 - NA, and 5 - NA respectively. But there is a single family residence on the property as well. Do we go by mixed-use property rules and report on the manufactured home community since it has more square footage, etc?

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#2261938 - 11/01/21 08:56 PM Re: Been Out of HMDA for Years -Simple Question Tesla
Compliance NABW Offline
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As the property as a whole is a Multifamily Dwelling, I would go with "Manufactured Home," "NA," and "NA." So, yep, what you have.

2. Multifamily dwelling. For a covered loan or an application for a covered loan related to a multifamily dwelling, the financial institution should report the construction method as site-built unless the multifamily dwelling is a manufactured home community, in which case the financial institution should report the construction method as manufactured home.

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