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Home As Collateral Business Purpose-Reportable?

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Question: 
I have a business purpose loan to purchase commercial real estate. The client is allowing his home to be taken as collateral along with the commercial real estate. It's a first mortgage on the home. Could this be a HPML? Do any RESPA disclosures apply and is it HMDA reportable?
Answer: 

A business purpose loan is not subject to Reg Z or RESPA. This loan would not be subject to HMDA reporting as it is neither a purchase, home improvement nor a refinance.

If this loan is later refinanced and is still secured by residential real estate, it will be HMDA reportable as a refinance at that time.

First published on BankersOnline.com 7/1/13

First published on 07/01/2013

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