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Dwelling as secondary collateral

Question: 
The primary collateral for a loan is business assets, although a dwelling was also taken as collateral. Is this loan not reported for HMDA?
Answer: 

HMDA reporting is not dependent upon whether the dwelling is primary or secondary collateral. Any consumer purpose loan that has a HMDA defined dwelling as collateral (all or part), is reported for HMDA. A business purpose loan that is for purchase, refinance (plain refinance or cash out refinance) or home improvement that has a dwelling as all or part of the collateral is HMDA reportable.
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First published on 02/17/2019

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