Good morning:

I know it's early to be asking this question, but here goes.
I thought that if you have a multi-family 1-4 units that would be HMDA reportable.
Would then anything above 1-4 not be HMDA reportable?

Thanks

multifamily units are reportable as HMDA, multifamily is defined as 5 or more family. Also 3 duplexes (6 units) is not multifamily as the units are 1-4 family. A mobile home park with 10 mobile homes is also not multifamily. An apartment complex with 5 units would be multifamily and reportable as such. See HMDA Getting it Right for guidance.

Thanks for responding...

Now I am confused, because I printed up some of the getting it right pages and they discuss loans on condos & cooperatives as 1-4 family dwellings.
So basically you need to really know the # of families living in the building and if there are 5 or more families
then it is HMDA reportable?

That sounds contradicting???

Lisa

Condos and coops are considered 1-4 family because each unit is looked at as a separate dwelling. The coding for multifamily properties is different than for 1-4 family dwellings, but they all need to be reported on the HMDA-LAR.

Bean,

A 1-4 family dwelling is any residential dwelling with less than 5 units. 5 or more units make a multi-family unit. The units do not have to be owner occupied. And if you have 5 families living in a 10 bedroom house, it is not a multi-family unit, it is a 1-4 family unit. 1-4 and multi refers to the design of the unit. Was it designed for 1 family to live in or was it designed for multiple families to live in?

Condos and cooperatives are individual 1-4 family units under one roof, each unit has its own deed and individual owners. When you make a loan to someone for a condo you do not have a lien on the whole condo complex, just the individual unit that the person is buying or refinancing.

Take a 50 apartment complex. If the owner of the complex “rents” each apartment then it is a multi-family unit. If the owner decides to make the “apartment” complex a “condo” complex and starts “selling” and deeding the individual “apartments”, they now become 1-4 family units.

I hope this helps, I know what I’m trying to tell you, but I’m not sure if I did a very good job of it in writing.

I just looked at my 2002 Mastering HMDA book and realized while we are on this multi-family subject, I see that code #4 of multi-family will no longer be an option in 2004.

What does that mean for 5 or more family properties???

HELP

Thanks

In 2004 you'll report:

Purpose:
1. Home Purchase
2. Home improvement
3. Refinancing

Property Type:
1. 1-4 Family (other than manufactured housing)
2. Manufactured housing
3. Muti-family

Let me just add here that it is a VERY common misperception that Apartment buildings are not HMDA reportable.

Some of the biggest challenges are with the Commercial Real Estate departments that may provide financing to purchase or refi an apartment. Most of the lenders generally deal with commercial property, and they think of apartment as "Investment" property.

The fact that it is RESIDENTIAL investment property seems to escape them.

It's also a good idea to check how these properties are getting reported on your Call Report. Multi-family dwellings should NOT be reported on line RC-C 1e. They belong on RC-C 1d.

Yes. I find quite frequently that our lenders assign the collateral code pertaining to "commercial real estate"......even though we have a separate code for "multi-family dwellings."

duh

How about a loan to refinance the purchase of an assisted living facility. Would it be HMDA reportable, and if so if it has ten beds would it be a multi-family or a 1-4 family?

I would report the loan. If the facility has 10 separate apartments, I would report as multi-family. If it is more of a group home type arrangement, say with 5 bedrooms sleeping 2 each, and common living areas, I would report as 1-4 family.

Actually I think the last scenario would be more complicated. An "assisted living facility" is basically a service enterprise. (See CRA Data Collection Guide) Loans to include as small business include: "service enterprises such as hotels, motels, laundries, automotive service stations and nursing homes and hospitals operated for profit"

The idea being that the clients are paying for the assistance as part of their room and board verses a typical "rental" housing scenario. If it were 10 rooms rented to individuals with no services, I'd lean on HMDA but if it is assisted living, with services being provided to allow for the ability to live independently or in a nursing home, I'd call it a type 1 small business loan (with 10 rooms). If it were a home used for assisted living (the smaller scenario presented) I'd call it a type 3 (other business loans which are not reported for CRA purposes)