I am giong to put this on our HMDA LAR but thought I'd just double check to make sure my head is in the right place!

We have a loan to refinance an assisted living facility which consists of 51 apartment style units that are rented out to people with disabilities. I'm listing this as multi family right??

Added bonus: there is an income restriction on the residents and they must be low or moderate income so this is going to be a community development loan too

Are there any arguments as to why this shouldn't be HMDA?

http://www.ffiec.gov/hmda/pdf/00news.pdf

Q. Are nursing homes, dormitories, fraternity/sorority houses, assisted living and retirement homes to be reported on HMDA?

A. Nursing homes, dormitories and sorority/fraternity houses are viewed as temporary housing and are not HMDA reportable since they were not built for permanent residency. In addition, a nursing home is more like a hospital in that it provides medical care, which is usually constant and extensive.

Assisted living and retirement homes are viewed as dwellings that individuals reside in permanently and are HMDA reportable. In fact, in most cases the “home place” has been sold by the individuals who choose these homes as their new “permanent” dwellings.

Thanks Dan, I just needed a little assurance!