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#634488 - 11/06/06 04:35 PM Commercial HMDA
notuntermywatch Offline
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Joined: Jun 2006
Posts: 392
MN
We have a mixed use property that is commercial and residential that we are making a home improvement loan on. It qualifies as HMDA and the borrowers are individuals. I'm blanking on how we complete the ethnicity, race, and gender sections since we didn't give them a GMI form to fill out since it was in the commercial area.

Any thoughts?

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Lending Compliance
#634489 - 11/06/06 04:42 PM Re: Commercial HMDA
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Why wouldn't the commercial area be providing the GMI disclosure for applicable loans? The collection of GMI for HMDA purposes is not dependent on whether the loan request is for business or consumer purposes.

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#634490 - 11/06/06 05:34 PM Re: Commercial HMDA
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
In other words - You screwed up.
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#634491 - 11/06/06 06:50 PM Re: Commercial HMDA
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Quote:

In other words - You screwed up.



Yeah, I would agree. But I would look very closely at the square footage or rental income. The GIR booklet allows an FI to use either one of those factors and the FI can apply it on "case by case basis" in deciding if it will report loan.
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#634492 - 11/06/06 08:04 PM Re: Commercial HMDA
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
I agree ACBbank, but you have to be a little more careful in your determination for HI loans then you do for a purchase or refinancing. The poster said it qualified as a HMDA loan and I based the answer on that. If the improvements were done to the residential portion then it is HI regardless of square footage or income production. And if the improvements were something that improved the entire structure, such as replacing the heating system, it is HI if the structure is primarily residential.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#634493 - 11/06/06 09:41 PM Re: Commercial HMDA
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Quote:

I agree ACBbank, but you have to be a little more careful in your determination for HI loans then you do for a purchase or refinancing. The poster said it qualified as a HMDA loan and I based the answer on that. If the improvements were done to the residential portion then it is HI regardless of square footage or income production. And if the improvements were something that improved the entire structure, such as replacing the heating system, it is HI if the structure is primarily residential.



As always Dan, you bring up a valid point. The breakdown for HI does require to be more specific then a purchase or refi.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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