Hi there! I have a question about Property Value and CLTV that I'm not finding much guidance on - would love to hear what everyone thinks.

If we are doing a HMDA-reportable loan, and, as collateral, we are using a dwelling PLUS a piece of non-dwelling collateral (car, cash deposit, land, etc.), for property value, do we report just the value of the dwelling, or do we report the value of the dwelling PLUS whatever the value of the additional collateral is? This question also then translates into CLTV. I believe we would include the value of all collateral, as we relied on it for making the credit decision, and the commentary says "A financial institution reports the property value relied on in making the credit decision." However, their use of the word 'property' instead of 'collateral' bothers me.

I'm looking at the moment at a commercial loan that was approved at 80%, based on the dwelling's value plus a cash deposit that the Bank will be holding. Without the cash deposit, the CLTV would have been over 100%. Do we include the value of the deposit held in property value (and in turn, CLTV)?

Yes.

You include all values considered in the decision for your value and for calculating CLTV. Doesn't matter if it's cash, a backhoe or plain dirt.

Thank you! That is what I was thinking but couldn't find it exactly spelled out anywhere.