79 With respect to the example raised by a creditor and two national creditor associations – three four-unit buildings operated as a 12-unit apartment complex, the text of the rule makes clear that a four-unit residential building would be a dwelling, but a 12-unit apartment complex is not. Thus a transaction secured by a four-unit residential building would be covered by the rule, but a transaction secured by the entire 12-unit apartment complex would not be. Because this question can be analyzed in a straightforward manner by reference to the text of the rule, the Bureau does not believe that further commentary is needed for this to be apparent.

Dear HMDA Respondent,

PURPOSE OF NOTIFICATION
In preparation for the September 2015 public release of the calendar year 2014 HMDA data, the Federal Reserve Board’s HMDA Operations unit is currently conducting their analysis of the data to identify possible misreporting and to give institutions the opportunity to revise their data file.

DATA FIELD TO BE VERIFIED: PROPERTY TYPE REPORTED AS MULTIFAMILY DWELLING
Definition: A multifamily dwelling is a SINGLE structure that contains five or more 1-to-4 family dwellings.

Below are examples of loans reported erroneously with the property type of multifamily; all below loans scenarios are a loan for MULTIPLE 1-to-4 family dwellings or MULTIPLE manufactured housing.
• a single loan for five or more single 1-to-4 family dwellings and/or manufactured housing
• a single loan for multiple duplexes
• a single loan for multiple triplexes
• a single loan for multiple quadplexes
• a trailer park/community containing any number of manufactured homes

REQUIRED ACTION
Please review all loans reported with a property type of multifamily. Per the above information, please confirm the information as accurate or correct the property type to either 1-to-4 family or manufactured housing. So that we may monitor incoming revised data files due to this communication, please reply to this e-mail by simply adding to the existing subject heading either “Resubmitting” or “Verified as Accurate” and include the institution’s HMDA Respondent ID.

Please note that other e-mails will be going out as well regarding other data fields over the next few days. Since you may receive some of these other e-mails, we suggest that you wait to resubmit, if necessary, until Wednesday, April 22nd to minimize the number of necessary resubmissions. Lastly, if you are using the FFIEC HMDA Data Entry Software, please transmit the revised data file using the Export option, Submission via Web; you will receive the resulting edit report within one hour or less from the time of your transmitting the data. A response to the updated edit report is due by close of business Monday, April 27, 2015.