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#2270277 - 05/10/22 07:03 PM Non-Owner Occupied / Not primarily for a B/C Ppse
referwithcaution Offline
Junior Member
Joined: Feb 2022
Posts: 25
I have another question here:

We utilize two types of software for HMDA data input. One is for Commercial Applications and the other for Consumer Applications. I often times receive Applications from M.O's that are for Investment Properties. These are, naturally, for a business or investment purpose in my mind. However, this consumer-centric software does not allow me to select the option "primarily for a business or commercial purpose".

I have not done HMDA for more than six months at this point, so please bring me up to speed if I am off course on this.

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#2270279 - 05/10/22 07:15 PM Re: Non-Owner Occupied / Not primarily for a B/C Ppse referwithcaution
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,763
OK
There is no definition in Reg. Z for "investment properties". The only definition i know of in Reg. C for them is for owner occupancy with the direction to code anything that isn't a primary or secondary residence as "investment". I would tread lightly with the idea that anytime an LO throws out the word "investment" it must automatically be for business purpose. Lots of threads out there that discuss this, but again, Reg. Z is pretty specific about automatic business purpose exemptions, for non-owner occupied rent homes. There are no exemptions in Reg. Z whatsoever for "investment properties". There are consumer investment properties (i get a loan to buy out a sibling's interest in a family-owned property) and there are business purpose investment properties (a builder gets a loan to buy and flip a home).

I don't know if this helps with your software questions.
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#2270318 - 05/11/22 03:40 PM Re: Non-Owner Occupied / Not primarily for a B/C Ppse raitchjay
referwithcaution Offline
Junior Member
Joined: Feb 2022
Posts: 25
That certainly does help. Thank you for the thorough and thoughtful response.

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