Need some help here with a new loan booked. At 4:00 pm on Friday I can't think this one through clearly! Have a business purpose commercial loan secured by real estate that is zoned commercial. The wrinkle is there is a house on the same commercial property that the business stores its cement trucks & equipment on . The tenants in the house rent from the business owner (our customer). Is this CRA since the its zoned commercial and purpose is business?

It might be easier to think of it as NOT being HMDA.

Just my opinion...if the loan is to purchase the property where the home is located then I would report it as HMDA...I would also include it on my CRA as small business and if the examiner chooses to throw it out then so be it but I would rather have them decide on the questionable loans than to completely lose out on a possible CRA loan...

The facts CCB stated lead me to believe that the business already owns the property.

Ron, you are right our customer already owns the property and the tenants have been paying rent to him. Are you saying not HMDA because it's business purpose, or something else??

Thank you Ron, I found the thread. Quite a lengthy but very informative discussion. Thank God for BOL, it has saved lots of lawyer fees!

People helping others doesn't go out of style. Even for bankers

What was the purpose of the loan? This could potentially be a HMDA-reportable refi.

Nice oversight 'gal. I was assuming CCB was versed in "purpose" issues.

We have a number of people (read: lenders) who only think of the new money when we ask about purpose - they forget that if we are also paying off an existing loan with a lien on a dwelling it makes a BIG difference for HMDA.

Hi, I just saw the added posts. The purpose was working capital line of credit needs for the business. We took an all asset filing and the lien on real estate. Thanks for the help.

I'm bumping this since no one answered after I provided the purpose. HMDAgal would it still not be HMDa reportable?Since funds were used for business w.c. and not for refinance of the existing loan on home or h.i. we don't think it is hmda.

You are correct, this would not be reportable.

However, if you should refinance the loan in the future, it would be a reportable refinance.