Answer:
You will have a mixed-use property. You can apply any reasonable standard to determine if the primary use of the property is residential or the primary use is commercial. From my perspective, a property that has a motel and a single family residence would be primarily commercial purpose property just based on the number of units. But you'll have to determine what standard you want to apply. If the property's use is primarily commercial, the loan would not be HMDA reportable. If the property's use is primarily residential, then you would need to determine if the loan was primarily consumer purpose or business purpose under Reg Z. If business purpose, the loan would be reportable only if it was for the dwelling purchase, refinance, or for home improvement purposes. If for consumer purpose and secured by mixed use property that is determined to be primarily residential, it would be HMDA reportable.
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