In comparing the data reported on the LAR to the loan file on a multifamily loan, the LAR indicated the OCCUPANCY code of "2" (Not Owner Occupied). Based on my review of "HMDA Getting It Right" guidebook, all multifamily loans are to reported as a "3" (Not Applicable), unless the property is located outside an MSA or property in an MSA where the institution has no home or branch office, then it can be the actual occupancy status or "not applicable". Management is disputing my findings and I'm looking for an opinion......

If I am understanding your situation and question correctly, I believe you and your management are both right. Look on page 21 of the Getting It Right Book. It states For multifamily dwellings (houssing five or more families), and for any dwellings located in MSAs where you do not have home or branch offices or located outside MSAs, you

may either enter the code for "not applicable" or the code for the actual occupany status.

Hope this is what you were referring to.

Just today I needed a HMDA reporting question answered. Of course I posted the question on BOL first, but then went looking for further help since I needed an answer pretty quickly. I found this: HMDAHELP@frbog.frb.gov. I submitted my question and got a response within 3 hours! Very impressive if you have ever used their "hotline" - 3 days there. You might try it, plus you can always print off their answers and maintain them in your files for examinations. Good luck.

HMDA Getting it Right does state that multifamily loans are to be reported as "3" (Not Applicable). I actually had an error produce on the HMDA software indicating such. I had originally used "2" No owner occupied. Hope this helps.