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#71423 - 04/02/03 07:18 PM Reg. C HMDA - Occupancy
Andy_Z 10K Club Joined: Oct 2000 Posts: 27,749 On the Net	1-Owner occupied principal residence 2-Not owner occupied 3-Not applicable When would you use 3, vacation home? _________________________ AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#71424 - 04/02/03 07:24 PM Re: Reg. C HMDA - Occupancy
Anonymous Unregistered	I believe code 3 is used for multi-family dwellings and for 1-4 family dwellings that are not located in an MSA in which you have a branch office.
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#71425 - 04/02/03 07:26 PM Re: Reg. C HMDA - Occupancy
Skittles 10K Club Joined: Sep 2002 Posts: 13,965 TN	Or business loans to purchase or refinance residential property (i.e. apartment complex, etc.). _________________________ My Opinions Only
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#71426 - 04/02/03 07:29 PM Re: Reg. C HMDA - Occupancy
Dan Persfull 10K Club Joined: Aug 2002 Posts: 47,529 Bloomington, IN	Andy, we use 3 for multi-family properties. For vacation homes we use 2. However, if the vacation home is in a MSA where you do not have a branch office you may report 3. (I guess they're called MAs now aren't they, it'll take me awhile to break the habit of MSAs.) _________________________ The opinions expressed are mine and they are not to be taken as legal advice.
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#71427 - 04/02/03 07:34 PM Re: Reg. C HMDA - Occupancy
Dan Persfull 10K Club Joined: Aug 2002 Posts: 47,529 Bloomington, IN	Quote: Or business loans to purchase or refinance residential property (i.e. apartment complex, etc.). If the property is a multi-family, or the loan is made to a non-consumer, then 3 is correct. However, a business loan to an individual to purchase 1-4 rental properties should be reported as 2s, IMO. _________________________ The opinions expressed are mine and they are not to be taken as legal advice.
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#71428 - 04/02/03 07:50 PM Re: Reg. C HMDA - Occupancy
hmdagal Power Poster Joined: Dec 2002 Posts: 3,841	We also have an occasional home improvement application where we don't know if the owner lives in the property or not (the applicant does, but is not the owner). We report those applications with a '3'.
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#71429 - 04/02/03 08:51 PM Re: Reg. C HMDA - Occupancy
complylady Platinum Poster Joined: Jul 2002 Posts: 614 Michigan	See GIR Appendix A V 6 and 7. Use code 2 for vacation homes or second homes as well as rental properties. Code 3 is only for multifamily or is not located in an MA, etc. A HMDA loan to a business entity does not qualify for the code '3' unless it is multifamily. Our builder HMDA loans on 1-4 family dwellings are coded "2" for non owner occupied. Last edited by complylady; 04/02/03 09:01 PM.
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#71430 - 04/02/03 09:09 PM Re: Reg. C HMDA - Occupancy
Dan Persfull 10K Club Joined: Aug 2002 Posts: 47,529 Bloomington, IN	Quote: A HMDA loan to a business entity does not qualify for the code '3' unless it is multifamily or outside an MA or within an MA where you do not have an office. You are correct, I confused the race and sex being reported as NA for loans to business entities. _________________________ The opinions expressed are mine and they are not to be taken as legal advice.
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#71431 - 04/03/03 03:29 AM Re: Reg. C HMDA - Occupancy
David Dickinson 10K Club Joined: Nov 2000 Posts: 18,762 Central City, NE	Along this same line (I got stumped on this one today) what occupancy code do you give the following? Loan to purchase a tri-plex. The borrower will live in 1 of the 3 units and rent out the other two. Is this owner occupied (1) or not owner occupied (2)? _________________________ David Dickinson http://www.bankerscompliance.com
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#71432 - 04/03/03 04:06 AM Re: Reg. C HMDA - Occupancy
Dan Persfull 10K Club Joined: Aug 2002 Posts: 47,529 Bloomington, IN	Me and Mr. Lite vote 1. _________________________ The opinions expressed are mine and they are not to be taken as legal advice.
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#71433 - 04/03/03 12:42 PM Re: Reg. C HMDA - Occupancy
Skittles 10K Club Joined: Sep 2002 Posts: 13,965 TN	I think it's '1' if the structure is a 1-4 family and the owner lives there. _________________________ My Opinions Only
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#71434 - 04/03/03 01:44 PM Re: Reg. C HMDA - Occupancy
Andy_Z 10K Club Joined: Oct 2000 Posts: 27,749 On the Net	Agreed. It isn't multifamily and it is owner occupied. 1. _________________________ AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#71435 - 04/03/03 04:23 PM Re: Reg. C HMDA - Occupancy
swiggles Power Poster Joined: Aug 2001 Posts: 7,351	Quote: Our builder HMDA loans on 1-4 family dwellings are coded "2" for non owner occupied. How do you define "builder HMDA loan?" Wouldn't that be temporary financing, thus not reportable? We're a CRA reporting bank. A loan to a builder to construct a residence (a sold home, spec or otherwise) would be a CRA type 3 (small business loan secured by residential real estate). Am I way off in left field? _________________________ The more you sweat in training, the less you bleed in battle.......
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#71436 - 04/03/03 05:16 PM Re: Reg. C HMDA - Occupancy
swiggles Power Poster Joined: Aug 2001 Posts: 7,351	Quote: We also have an occasional home improvement application where we don't know if the owner lives in the property or not (the applicant does, but is not the owner). We report those applications with a '3'. Why would you not know? Wouldn't you ask during the application process? For sure, you would know prior to loan closing. Am I missing something? I don't think you can use "3" (N/A) because the occupancy status IS applicable for the type of loan applied for. _________________________ The more you sweat in training, the less you bleed in battle.......
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#71437 - 04/03/03 07:01 PM Re: Reg. C HMDA - Occupancy
hmdagal Power Poster Joined: Dec 2002 Posts: 3,841	Quote: Quote: We also have an occasional home improvement application where we don't know if the owner lives in the property or not (the applicant does, but is not the owner). We report those applications with a '3'. Why would you not know? Wouldn't you ask during the application process? For sure, you would know prior to loan closing. Am I missing something? I don't think you can use "3" (N/A) because the occupancy status IS applicable for the type of loan applied for. If the applicant for a home improvement loan rents, we don't routinely ask if the owner of the property lives there with him. Our regulator confirmed that this was an appropriate use of the occupancy code of '3'.
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#71438 - 04/03/03 07:21 PM Re: Reg. C HMDA - Occupancy
swiggles Power Poster Joined: Aug 2001 Posts: 7,351	Quote: If the applicant for a home improvement loan rents, we don't routinely ask if the owner of the property lives there with him. Our regulator confirmed that this was an appropriate use of the occupancy code of '3'. hmdagal.....thanx for the info. I did not know that. In this profession, you learn something new every single day!! _________________________ The more you sweat in training, the less you bleed in battle.......
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#71439 - 04/03/03 07:35 PM Re: Reg. C HMDA - Occupancy
hmdagal Power Poster Joined: Dec 2002 Posts: 3,841	Shirley, As many HMDA transactions as we have, it's not something I see very often, but it does happen (hence my phone call to the feds).
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#71440 - 04/07/03 08:12 PM Re: Reg. C HMDA - Occupancy
David Dickinson 10K Club Joined: Nov 2000 Posts: 18,762 Central City, NE	Thanks for the replies on the tri-plex question. _________________________ David Dickinson http://www.bankerscompliance.com
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#71441 - 04/08/03 06:34 PM Re: Reg. C HMDA - Occupancy
Anonymous Unregistered	I have another one...what if you have two buildings, each with 4 units, but have the same street address? I.E., 123 Hwy 4, Units 1-8. Is this a multi-family, or a 1-4 family since each unit is technically a 4 family?
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#71442 - 04/08/03 06:59 PM Re: Reg. C HMDA - Occupancy
Princess Romeo Power Poster Joined: Jun 2001 Posts: 8,272 Where the heart is	Quote: Is this a multi-family, or a 1-4 family since each unit is technically a 4 family? I believe this would be reported as a 1-4 family. _________________________ CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#71443 - 04/08/03 07:33 PM Re: Reg. C HMDA - Occupancy
Anonymous Unregistered	I agree. You have two quadraplex dwellings.
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#71444 - 04/09/03 03:08 PM Re: Reg. C HMDA - Occupancy
complylady Platinum Poster Joined: Jul 2002 Posts: 614 Michigan	The builder loans I am referring to, and are common in this area with other institutions also, are construction perm loans. They are assumable and are usually assumed when the house is completed and sold. The assumptions are then reported as HMDA transactions also as we approve the borrowers. You are correct in that just a construction loan (spec) is not HMDA reportable as that would be a temporary loan.
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