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#1822735 - 06/12/13 02:30 PM Commercial Loan
dac Offline
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Joined: Sep 2009
Posts: 234
The bank recently did a Commercial loan to refinance an SBA loan, mortgage loan and to payoff credit card debt. We took six properties as collateral. Two properties are leased residential, three properties are mixed use and one houses a business on the first floor and the second floor is currently vacant but had been previously tenant occuipied. The loan is to the same borrower. Is this HMDA reportable? If so, which property would we use for HMDA?

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#1822756 - 06/12/13 02:52 PM Re: Commercial Loan dac
raitchjay Offline
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Joined: Oct 2009
Posts: 9,083
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"Leased residential" means they're dwellings, correct? If so (or if any of the mixed-use buildings meet the definition of a dwelling), then yes, it would be a HMDA reportable refinance. You could either just choose one of the dwellings (if there's more than one) and report it or report the loan using multiple entries and allocating the loan amount amongst the properties dwellings.
Last edited by raitchjay; 06/12/13 03:03 PM.
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#1822757 - 06/12/13 02:55 PM Re: Commercial Loan dac
raitchjay Offline
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Joined: Oct 2009
Posts: 9,083
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I think back in the early 2000s (before i was in banking) the rules changed on commercial purpose and HMDA. What you're left with nowadays is that loans that are primarily for a commercial purpose and secured by commercial property can still be reportable if the loan is incidentally also secured by a dwelling.
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