I have a property that has 18 SRO units. No kitchen, no bath. There is a community kitchen and bath on each floor of the property. The rents are below the HUD qualify rents for an efficiency apartment for that area. 12 of the 18 units are also mostly paid through a special program to get people off the streets. It is not transient housing. The loan is a refinance so I have to report on the HMDA LAR but can I double dip as a multifamily?

A yes would be greatly appreciated

Any thoughts?

Decided to go ahead and double report on the HMDA LAR and as a CDL- Affordable housing

Sorry WAB didn't see your question. I believe since you went the HMDA route you would be clear to go for CD. If the use of the property isn't short term in nature then I would say you are good to go on the affordable housing front.

Excellent thanks. Property is not temporary housing so I think we are on the same page.