If a loan is secured by a dwelling and a certificate of deposit, should the balance of the CD also be included in the Property Value?

From everything I read in the reg, it appears "property' references real estate. Where a CD is not real estate, I would exclude it. Especially where the option is available to use NA if a decision should ever be made without relying on property value. Adding the balance of a CD would also skew HMDA reports meant to reflect property values.

If the value of the CD was used in calculating the CLTV then you include it.

6. Property. A financial institution reports the combined loan-to-value ratio relied on in making the credit decision, regardless of which property or properties it used in the combined loan-to-value ratio calculation. The property used in the combined loan-to-value ratio calculation does not need to be the property identified in § 1003.4(a)(9) and may include more than one property and non-real property. For example, if a financial institution originated a covered loan for the purchase of a multifamily dwelling, the loan was secured by the multifamily dwelling and by non-real property, such as securities, and the financial institution used the multifamily dwelling and the non-real property to calculate the combined loan-to-value ratio that it relied on in making the credit decision, § 1003.4(a)(24) requires the financial institution to report the relied upon ratio. Section 1003.4(a)(24) does not require a financial institution to use a particular combined loan-to-value ratio calculation method but instead requires financial institutions to report the combined loan-to-value ratio relied on in making the credit decision.

Dan - would you please provide the source for the #6? I want to bookmark it. when I read through 1003.4(a)(28) and comments 1-4, I didn't see any reference to non-real property taken as collateral. Thanks!

It's from the 2022 A Guide to HMDA Reporting: Getting it Right / page I-62

Melissa - the cite I posted is from 1003.4(a)(24) - comment 6 in the OSI.