I have a question on HMDA that should be easy to answer but I'm drawing a blank. We have a loan to purchase a vacation home. The customer is using their current home as security for the purchase. We are not taking any security interest in the vacation home. If I'm reading HMDA right I would use the security address as the address for reporting. That just doesn't make sense to me so I'm hoping I read it wrong.
It makes more sense to me to use the vacation property address and say that it was a non-owner occupied purchase.

If anyone has any guidance could you help me out.

Thanks,

Jamie

You report the census information on the property securing the loan in a purchase transaction, and the property being improved in a home improvement transaction.

Page D-11 of HMDA GIR

FFIEC A Guide to HMDA Reporting page A-12, Appendix A, C - Property Location - states for home purchase loans secured by one dwelling, but made for the purpose of purchasing another dwelling, report the property location for the property in which the security interest is to be taken.

Thank you for confirming that.