Hi all -

I have a commercial loan collateralized by a dwelling, equipment and inventory. The lien on the real estate is a 4th position. In order to calculate the LTV for HMDA purposes, I am going to have to remove the value of the equipment and inventory and calculate the total outstanding of the 4 loans against just the real estate value?

Report what you used.

1004.4(a)(24)-6. Property. A financial institution reports the combined loan-to-value ratio relied on in making the credit decision, regardless of which property or properties it used in the combined loan-to-value ratio calculation. The property used in the combined loan-to-value ratio calculation does not need to be the property identified in § 1003.4(a)(9) and may include more than one property and non-real property.

Thank you.