We recently purchased two seasoned low-mod first time homebuyer mortgages loans orignated by a non-profit organization. Where would we categorize these loans on our CRA data entry?

These mortgages fall under HMDA. Purchased loans are reportable.

I agree with this. These are HMDA reportable. Typically you wouldn't get credit for both HMDA and CRA with examiners - or at least that has been our experience.

Duplicate filing for HMDA and CRA are allowed for certain ISB transactions, for multi-family housing which can be HMDA and community development if qualified, and for refinances of small business loans (types 1 and 3) secured by residential real estate. (Type 1 would be less than 50% secured by residential r.e., and type 3 would be 50% or more secured by residential r.e.)

Under the refi carve out, examiners will adjust if there is enough of an overlap to skew reporting.

This is discussed in the Q&A.