HMDA if Borrower's Primary on Same Parcel?

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Question:

I have an application for a refinance of existing debt secured by commercial real estate (a small mobile home park). The twist is, the borrower's primary residence is on the same parcel. The debt we are refinancing is held by another FI and was done for business purposes, as ours will be. Does HMDA apply? I'm inclined to say no.

Answer:

If the home is included in the existing lien and your new lien, and you have the same borrower this is a refinance for HMDA. Check the mortgage to see if that structure was excluded or is part of your collateral. If the residence is covered by the lien, the loan is a refinance for HMDA.

First published on BankersOnline.com 10/22/12