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#1920340 - 05/06/14 02:42 PM Mixed purpose loan and CRA
Live&Learn Offline
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Live&Learn
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I have a loan to purchase a daycare and refi a rent house.

It is a hmda loan because of the refinance of the rent house.
Since it is hmda, does this mean I cannot use this for CRA?
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CRA
#1920366 - 05/06/14 03:25 PM Re: Mixed purpose loan and CRA Live&Learn
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You can only double report in 2 circumstances:

a loan can be reported for HMDA as a multi family and also as a community development loan

a loan that is a small business refinance that is also HMDA reportable can remain a small business refinance. If the primary (>50%) of the collateral is residential real estate, the loan would be type 3 small business. If the primary collateral is CRE or something else, the loan will be type 1 small business. Refer to the call report instructions for determining what category to place a loan. Also, the FFIEC q and a has the information about the double reporting of a small business refinance.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1920423 - 05/06/14 05:22 PM Re: Mixed purpose loan and CRA Live&Learn
Live&Learn Offline
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The CRA part I would want to report would be purchasing the daycare. Technically the daycare wasn't hmda it was just on the same loan that the hmda refi was on...

Does this make any sense?
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#1920431 - 05/06/14 05:37 PM Re: Mixed purpose loan and CRA Live&Learn
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, but having that residence on the loan can trigger HMDA. You can't split a loan up for reporting. It is in or it is out.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1920449 - 05/06/14 06:01 PM Re: Mixed purpose loan and CRA Live&Learn
Live&Learn Offline
100 Club
Live&Learn
Joined: Aug 2012
Posts: 241
South
Okay, that answers my question! Thanks again Kathleen!
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