Skip to content
GeoDataVision
Thread Options
#2273420 - 07/26/22 08:57 PM Home Improvement - Which address
dmcpherron Offline
New Poster
Joined: Feb 2021
Posts: 7
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.

Return to Top
HMDA

   
HMDA Academy
#2273434 - 07/27/22 01:01 PM Re: Home Improvement - Which address dmcpherron
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,935
Galveston, TX
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2273436 - 07/27/22 01:05 PM Re: Home Improvement - Which address dmcpherron
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,962
Bloomington, IN
I was under the impression to always report the address of the property being improved.

That was before the 2018 revisions.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2273441 - 07/27/22 02:33 PM Re: Home Improvement - Which address dmcpherron
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,643
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.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2273481 - 07/27/22 08:16 PM Re: Home Improvement - Which address dmcpherron
dmcpherron Offline
New Poster
Joined: Feb 2021
Posts: 7
Thanks for the responses. That is what I needed.

Return to Top

Moderator:  SMQ, CRCM