We have an LLC that bought a house in FL. The guarantors will use it as a second home for part of the year. It will be a short-term rental the remainder of the year. Would this be considered transitory and excluded from HMDA?

This has been discussed at length before. Here is one discussion, make sure you read the entire couple of pages. This link takes you to the end.

https://www.bankersonline.com/forum...elling-to-be-airbnb-property#Post2231500

We have an LLC that bought a house in FL. . . . It will be a short-term rental the remainder of the year.

IMHO this is a reportable investment property. The LLC intends to generate income from the property.

PDF page 167 in the 2023 GIR.

If a corporation purchases a property that is a Dwelling and uses it for the long-term residence of its employees, the property is an investment property, even if the corporation considers the property as owned for business purposes rather than investment purposes, does not generate income by renting the property, and does not intend to generate income by selling the property. If the property is for transitory use by employees, the property would not be considered a Dwelling. Comment 4(a)(6)-4.

I just realized I asked the same question recently (Residential property used as worker housing/office). With this being considered transitory housing and given the commercial/business component when it comes to the purpose, would you see such a situation reported on the CRA LR then...or neither (HMDA or CRA)?

Can you elaborate on the " worker housing" use of the property?

The following was my question to the loan officer..."It was noted that the subject 1-4 family residential structure will house a set of workers and serve as an equipment yard. Could you elaborate on the workers’ own living situations? Do they have separate homes of their own where they will live outside of work, making this property more transitory housing, or will the subject property serve as their only full time home?"

There response: "The house sleeps crews in a transitory manner. "

Sounds like transitory housing and not reportable to me.

Great...have you ever heard of anyone changing the Call Code of such loans to 1e (CRE) and reporting it on the CRA LR?