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#2302335 - 10/08/24 01:13 PM What Amount for HMDA Submission?
burkemi Offline
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Posts: 556
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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HMDA

#2302337 - 10/08/24 02:13 PM Re: What Amount for HMDA Submission? burkemi
Dan Persfull Offline
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Dan Persfull
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Posts: 47,763
Bloomington, IN
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.


You may need to explain this more clearly. Are the loans cross collateralized with the property which makes them both secured by the property or are they just cross collateralized for default purposes.

If both loans are secured by the property then you have 2 home purchase loans to report. One for $24.25MM and one for $15.21MM.
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#2302338 - 10/08/24 02:43 PM Re: What Amount for HMDA Submission? burkemi
burkemi Offline
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Joined: Nov 2013
Posts: 556
Just cross-collateralized for default purposes.

So that would mean only the 24.25 is reportable - correct?
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#2302342 - 10/08/24 03:15 PM Re: What Amount for HMDA Submission? burkemi
Dan Persfull Offline
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Dan Persfull
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Posts: 47,763
Bloomington, IN
Correct.
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#2302355 - 10/08/24 06:02 PM Re: What Amount for HMDA Submission? burkemi
burkemi Offline
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Joined: Nov 2013
Posts: 556
Thank you!
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