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#2189466 - 08/16/18 07:40 PM Reg B Dwelling vs. HMDA Dwelling
Jen J Offline
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Joined: Dec 2015
Posts: 144
I feel like the newest HMDA rule and commentary did a pretty good job of defining "dwelling;" however, Regulation B is still more ambiguous. Are there residences that could be considered to be "dwellings" under Regulation B but not HMDA?

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Lending Compliance
#2189490 - 08/16/18 09:06 PM Re: Reg B Dwelling vs. HMDA Dwelling Jen J
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Reg B: (2) Dwelling. The term "dwelling" means a residential structure that contains one to four units whether or not that structure is attached to real property. The term includes, but is not limited to, an individual condominium or cooperative unit, and a mobile or other manufactured home.
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#2189520 - 08/17/18 01:02 PM Re: Reg B Dwelling vs. HMDA Dwelling Jen J
Adam Witmer Offline
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Joined: Sep 2010
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The 2013 4th quarter edition of the Fed's Consumer Compliance Outlook explains the difference in the definition of dwelling between Reg B and Reg C:

The regulations also define dwellings differently. Under Regulation B, a dwelling is limited to residential structures with one to four units.17 But Regulation C defines dwellings to contain any number of units, and it excludes recreational units and “transitory residences such as hotels, hospitals, and college dormitories.”
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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