I have just completed the CRA guide again and I still cannot decide on this one. The loan is a non-consumer to purchase a condo in Fl. and it is secured with th CD...should I keep it on the LAR? Thanks fo your help

P.S. This is the only way holding me up from submitting the LAR....

The regulation requires an institution to report data to its supervisory agency about home purchase loans, home improvement loans, and refinancings that it originates or purchases, or for which it receives applications; and to disclose certain data to the public. If the request is for purchasing of a condo, it's HMDA reportable.

I'm a little confused. Are you trying to report this as a Small Business Loan on the CRA LAR? or as a Real Estate loan on the HMDA LAR?

Was the loan orginated for a small business purpose?

I think he is getting his LR and LAR mixed up. Since he said he read the CRA guide, I would guess he meant LR.

If that is the case, by non-consumer do you mean business purpose. If that is the case, it would be CRA reportable because it is small business secured by a CD.

It would never be HDMA because it has to be secured by RE to be a purchase on the LAR.

Yes, it is a business purpose. Thanks for the help.