We have a question about a loan that recently closed that is HMDA applicable, but it’s not clear how we should report it since the structure is a little unusual.
- There are 2 loans to the same borrower, both related to a 200-unit multifamily property
o $24.25MM loan that is secured against, and for the acquisition and renovation of, a 200-unit multifamily property
o $15.21MM loan to the general partner, secured against general partner interests, to allow the borrower to get to 90% loan / 10%
equity
o The loans are cross-collateralized such that default of the $24.25MM loan results in a default of the $15.21MM GP loan. A default
of the GP loan does not, however, result in a default of the $24.25MM loan
- The question we have is -What amount should be reflected in the HMDA submission? $24.25MM (just the 200-unit secured loan) or
$39.46MM (total of both loans)?
Any input would be greatly appreciated!
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