For HMDA reporting on a Home Improvement Loan, what is the correct address to report? The address of the property securing the loan or the address of the property receiving the improvements? 1003.4(a)(9) reads as to always report the address of the property securing. However, I was under the impression to always report the address of the property being improved.

Paragraph 4(a)(9)(i)
1. General. Except for partially exempt transactions under § 1003.3(d), § 1003.4(a)(9)(i) requires a financial institution to report the property address of the location of the property securing a covered loan or, in the case of an application, proposed to secure a covered loan. The address should correspond to the property identified on the legal obligation related to the covered loan. For applications that did not result in an origination, the address should correspond to the location of the property proposed to secure the loan as identified by the applicant.

I was under the impression to always report the address of the property being improved.

That was before the 2018 revisions.

I agree with Dan. The old rules absolutely allowed you to choose either the property securing the loan or the property being improved. However, the pre-amble to the 2015 final rule goes on and on about the Dodd-Frank Act requirements and how the final rule requires the address of the property securing the loan.

Thanks for the responses. That is what I needed.