HMDA purchase?

An individual is purchasing a a 1-4 family residence which has a detached garage with several apartments.

Both properties will be leased to two fraternity chapters for their use. It would seem that this would be "transitory" housing, and NOT HMDA reportable.

Is it the use of the property by the leasee that designates the property as a "dwelling" or not for HMDA reporting purposes?

If yes, then I believe this is NOT HMDA reportable.

If no, then it would seem to be reportable.

Thanks in advance for any help.

I would consider this to be transitory housing and not reportable.

That is what I do here - I just make sure and document the file.