CRA or HMDA?

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Question:

Our bank has made a loan to a corporation that owns and operates mobile home parks. The purpose of the loan is to refinance one park with 150 pads. Some of the homes in the park are owned by the corporation and rented out to individuals, and some pads are rented to individuals that own their own mobile homes. Is this a CRA small business loan or a multifamily HMDA refinance loan?

Answer:

Based on your comments I am assuming you have the Mobile Homes as security and your loan refinanced another loan that was also secured by the Mobile Homes.

You have a loan that meets the definition of a refinance under HMDA, however it would not be multifamily - it would be manufactured housing.

First published on BankersOnline.com 9/19/05