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Residential Home Improvement-Address to Report

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Question: 
Commercial customer is using one residential investment property as collateral to do improvements to another residential investment property. Is this HMDA reportable? if so, which address do I report; and is the purpose "home improvement"?
Answer: 

From 1003.2

(i) Home improvement loan means a closed-end mortgage loan or an open-end line of credit that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which the dwelling is located.

(d) Closed-end mortgage loan means an extension of credit that is secured by a lien on a dwelling and that is not an open-end line of credit under paragraph (o) of this section.

(o) Open-end line of credit means an extension of credit that:

(1) Is secured by a lien on a dwelling; and

(2) Is an open-end credit plan as defined in Regulation Z, 12 CFR 1026.2(a)(20), but without regard to whether the credit is consumer credit, as defined in § 1026.2(a)(12), is extended by a creditor, as defined in § 1026.2(a)(17), or is extended to a consumer, as defined in § 1026.2(a)(11).

From 1003.4

(9) The following information about the location of the property securing the covered loan or, in the case of an application, proposed to secure the covered loan:

First published on 04/29/2018

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