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Filling out a LAR

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Question: 
When a loan is secured by two properties, which one do I list on the LAR? A customer's existing home and the home he is purchasing are being used to secure the loan.
Answer: 

For a purchase, when there are multiple pieces of collateral, you should report the property being purchased. If you do a search on the word multiple you will find the instructions in the HMDA Getting It Right Guide, available at the FFIEC HMDA website.

4(a)(9) Property location.
1. Property location—multiple properties (home improvement/ refinance of home improvement).For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/LAR (with unique identifiers) and allocating the loan amount among the properties.

2. For a home purchase loan, an institution reports the property taken as security. If an institution takes more than one property as security, the institution reports the location of the property being purchased if there is just one. If the loan is to purchase multiple properties and is secured by multiple properties, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/ LAR (with unique identifiers) and allocating the loan amount among the properties.

First published on BankersOnline.com 8/30/10

First published on 08/30/2010

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