I need some help with a HMDA question. I know that purchase or improvement of multi-family dwellings is a HMDA reportable transaction. The question has been put to me, "Are there specific types of businesses (Sole Proprietor, LLC, Partnership, Corporations) that are exempted?" My reading of HMDA leads me to believe that there are no exemptions. Appendix A has a section that explains the LAR codes in greater detail. The section about Race, Sex, and Income makes provision for those borrowers who are not "natural persons". The Staff Commentary also discusses loans made in the commercial lending department. Am I missing something here?

You are correct in your assumption that there are no exempt entities. It is sometimes difficult for lenders to understand that loans for business purposes (i.e. rental property) are HMDA reportable.

You are correct, there is no "business type" exemption for HMDA. The only difference is the reporting codes as you mentioned.

If the loan is for the purpose of purchasing, refinancing, or rehabilitating the 1-4 family or multi-family dwelling or the property upon which the dwelling is located it is HMDA reportable whether the loan is to an individual or a business entity.