Not sure how unusual this is...but...if a renter of a 1-4 family property applies for a home improvement loan (despite the fact that they do not own the home) is this loan HMDA reportable?

Are you taking a lien on the property?

If the loan is to be unsecured but classified by your institution as home improvement then I would report it.

Loan is unsecured, but is "coded" as a home improvement loan on our front end system.

These were the 2 responses I got when I asked basically the same question...I would report it as a home improvement loan for HMDA purposes.

Home improvement loans are reportable if:

1. The loan is dwelling secured and any part of the proceeds are used for home improvement,

or

2. The loan is unsecured, any part of the proceeds are for home improvement, and the loan is classified as a home improvement loan by the institution.

However, the loan does not have to be classified on your call report or your system. If you segregate HI loans either my filling them in a separate area, color coded files, tabs, etc. then you have classified the loan. If I ask you, can you provide a list of all loans that had a HI purpose, can you provide me that list without doing a file search to see what the stated purpose was? If so, then you have classified the loan as a HI loan.

Thanks!