Would a construction perm loan to construct multifamily and single family housing be eligible to count as a community development loan?

Depends on whether the rental and single family houses serve primarily low to moderate income individuals and familes; or are revitalizing LMI geographies, or are in disaster areas or underserved nonmetropolitan middle income geographies.......

So this would count as a multifamily secured loan and be able to be reported as community development and hmda if it they are for moderate income families?

Multi-family housing construction loans that provide affordable housing for LMI are CD loans. They are not reported under HMDA. Doesn't matter where they are located as long as they provide affordable housing for LMI people.

does it matter that this is a construction perm?

are you saying construction to perm terpsfan?

I think CRAreg is saying temporary financing is not HMDA, but when you enter the permanent phase of the loan, it would be (I think).

If this is the case, I believe you have hit upon the highly unusual situation of being able to report HMDA and CD.

But you had better wait for confirmation from other posters. I am shooting from the hip and am way past my prime.

Construction to perm loans are reported for HMDA.

A construction only loan for affordable housing could be reported for community development. A construction to perm on the multi family can be reported for community development and HMDA but he SFR can not.

If it were a construction only loan on the SFR, you could report it for CD but since this is also the perm financing you are going to have to report that on the HMDA LAR hence you're going to have to exclude it from CD.

Loans for multi-family affordable housing are the only types of loans that can be reported for both HMDA and CD.

I think when it is secured by a multifamily dwelling that you can report it for both but I am not sure if this rule still applies if it is secured by both single family and multifamily dwellings. This stuff is so confusing.

Are you saying that you have one loan that is secured by both an SFR and a multi-family?

goodnight I hope that is not the case BnS!

but you said it so much better than I did!

Yeah it is a construction perm loan to construct apartments but some apartment buildings are only 4 units which would make them 1-4 family and not multifamily. I would like to report it as community development but do not know if I can.

terps, are the units all on one piece of property? All on one tax lot?

Yeah

The way we do it here is: if the property is all on one tax lot and there are more than 5 units, it is considered all one multi-family property.

There is one loan #, one piece of property, one tax lot.

But, I would check into the way your FI usually reports a situation like this and be consistent. You don't want to change the way things are usually done there just to be able to report this for CD. Another option, (if possible) ask your regulator how they want to see this reported. It really does come down to how he or she will look at it.

IMO, as long as this project really is going to be affordable housing, I'd report the loan both for HMDA and as a CD loan for affordable multi-family housing.

Any other opinions out there?

I am with BnS

report it on the Call as multi-family and put it on HMDA and as a CD, document the CD and move on....