HMDA or CRA?

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Question:

We have a loan that we would like your opinion on whether to report as HMDA or CRA? We don't want to double dip. The couple owns a general store with an apartment upstairs that they are currently living in. The loan is for them to build a home for themselves on the same property. The apartment would then be rental property. This loan was processed as a commercial loan. However, the loans purpose was to build the home.

Answer:

You have a consumer purpose loan and all consumer regulations apply. The collateral does not change the loan's purpose. I am assuming the loan is/will be secured by the GS/Apt and the new dwelling. IMO you have a HMDA reportable loan.

First published on BankersOnline.com 5/16/05