HMDA How to Report Loan for Apartment Complex

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Question:

I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?

Answer:

You can do either, but I recommend choosing one building and reporting it on one line of the LAR. Here's what Reg says:

Multiple Properties: [Commentary to 1003.4(a)(9) #1 & 2]
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 2/20/12