HMDA Filing Help

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Question:

I have one loan secured by three residential properties and all are HMDA reportable. Do I have to file a HMDA form for each property, and if so, would the loan amount be for the initial loan or would I divide the loan amount by the three properties and report for only a third of the loan amount?

Answer:

You need to refer to the Commentary to Section 203.4(a)(9) #1 & 2. I cannot answer your question, as it depends on whether this is a home improvement or home purchase loan. Below is the two commentaries I referenced.

Multiple properties:
Home improvement or refinance of home improvement. For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA-LAR (with unique identifiers) and allocating the loan amount among the properties.

Home purchase or refinance of home purchase. For a home-purchase loan, an institution reports the property taken as security. If an institution takes more than one property as security, the institution reports the location of the property being purchased if there is just one. If the loan is to purchase multiple properties and is secured by multiple properties, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA-LAR (with unique identifiers) and allocating the loan amount among the properties.

First published on BankersOnline.com 4/02/07