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#2273111 - 07/20/22 04:17 PM HMDA Property Value
dtew Offline
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Joined: Apr 2021
Posts: 15
When determining property value of multiple properties used as collateral, do we use to the total of all properties even though we only report one address?

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#2273112 - 07/20/22 04:23 PM Re: HMDA Property Value dtew
Tater Offline
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Joined: Jan 2006
Posts: 642
Missouri
From https://www.bankersonline.com/regulations/12-1003-004

Quote
(28) The value of the property securing the covered loan or, in the case of an application, proposed to secure the covered loan relied on in making the credit decision.

Official Interpretation
Paragraph 4(a)(28).
1. General. Except for partially exempt transactions under § 1003.3(d), § 1003.4(a)(28) requires a financial institution to report the value relied on in making the credit decision. For example, if the institution relies on an appraisal or other valuation for the property in calculating the loan-to-value ratio, it reports that value; if the institution relies on the purchase price of the property in calculating the loan-to-value ratio, it reports that value.

How did you underwrite the transaction? That will guide you. As long as you can document what you used, you report that.
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#2273114 - 07/20/22 04:26 PM Re: HMDA Property Value dtew
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
From page 82 in the 2022 GIR:

A Financial Institution reports the CLTV ratio relied on in making the credit decision, regardless of which property or properties it used in the CLTV ratio calculation.The property used in the CLTV ratio does not need to be the Identified Property and may include more than one property and non-real property. Comment 4(a)(24)-6.
Last edited by Dan Persfull; 07/20/22 04:30 PM.
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