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HMDA- Primary Residence Used to Purchase 2nd Home

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Question: 
We have a borrower that is using their primary residence (that does not have an existing lien) to purchase a second home. If I am understanding Reg C correctly, I would be reporting the loan as a purchase because that is what the funds are being used for. Would I then report it as a primary residence because the property that will have the lien is their primary residence or would it be a second home because that is what the funds are being used for?
Answer: 

It reverts to the property taken as collateral:

Paragraph 4(a)(6)

(6) Whether the property identified in paragraph (a)(9) of this section is or will be used by the applicant or borrower as a principal residence, as a second residence, or as an investment property.

Paragraph 4(a)(9)

1. Multiple properties with one property taken as security. If a covered loan is related to more than one property, but only one property is taken as security (or, in the case of an application, proposed to be taken as security), a financial institution reports the information required by § 1003.4(a)(9) for the property taken as or proposed to be taken as security. A financial institution does not report the information required by § 1003.4(a)(9) for the property or properties related to the loan that are not taken as or proposed to be taken as security. For example, if a covered loan is secured by property A, and the proceeds are used to purchase or rehabilitate (or to refinance home purchase or home improvement loans related to) property B, the institution reports the information required by § 1003.4(a)(9) for property A and does not report the information required by § 1003.4(a)(9) for property B.

First published on 12/01/2019

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