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Consumer purpose secured by rental property

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Question: 
Is a consumer loan secured by a non-owner occupied rental dwelling considered business purpose due to the collateral?
Answer: 

Collateral does not change loan purpose. A consumer purpose loan remains consumer purpose if secured by non-owner occupied residential real estate or any non-owner occupied real estate such as a store or office building. Similarly, a business purpose loan secured by residential real estate, even if owner occupied, remains business purpose for HMDA reporting.

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First published on 09/03/2023

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