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Real Estate Loan HMDA Reportable

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Would a loan be HMDA reportable when the purpose is to provide construction to permanent financing of a new home that will be used for short term rental use?

Assuming that the loan is designed as a combination construction/permanent financing for the home, it would appear the only question is whether a home used only for short-term rentals would be excluded as a "transitory residence" as described in Regulation C (HMDA) comment 2(f)-3.

I don't believe that "short-term rentals" of the dwelling would make it a transitory residence. I would consider the loan to be reportable as a home purchase loan.

First published on 10/24/2021

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