Mom and Pop take out a loan to purchase a hunting lodge. The loan is secured by the lodge. They will live in one of the units and rent the others out during hunting season.

The commentary to Reg. C talks about hotels being exempt because their occupants have principal residences elsewhere. The same would be true here, except for Mom and Pop.

Does Mom and Pop's loan secured by and for the purpose of purchasing a dwelling trump the hotel exemption?

Is this HMDA reportable?

I think the hotel would be considered transitory and therefore not reportable.

Yes, but the loan is for both purposes. Which one rules?

The square footage of what they will be occupying is less than the rest, yes? THat's one way.

I agree with Rizzo. For it to be a home purchase they have to be purchasing a dwelling. Therefore you must first determine if they are purchasing a dwelling. Mixed use property is dicussed starting on page D-5 of the GIR.

::pats herself on the back and shouts out a WOOT!WOOT::

You got me on that one Riz, I would have gone with purchase.