This year we are going to start reporting our consumer loans for Home Improvements. But we have a question regarding the census track to be used. Do we report the census track for the home we are improving or do we report the property where the client lives? These are unsecured loans. For mortgage loans we always report the property which will be the loan guarantee.

Thanks

If the loan is unsecured then it is not HMDA reportable.

Unless you classify it as a home improvement loan then it is.

You report the location of the property being improved.

The definition of a HI is:

Home improvement loan. A home improvement loan is (a) any dwelling-secured loan to be used, at least in part, for repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which the dwelling is located, and (b) any loan not secured by a lien on a dwelling (i) that is to be used, at least in part, for one or more of those purposes and (ii) that is classified as a home improvement loan by the institution.


For home improvement loans you report the property that is being improved.