HMDA Reporting & Commercial Loans

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Question:

This question is in regards to Commercial lending compliance. We have a loan to a Cooperative Homes organization who took out a LOC for improvements to the co-ops (i.e. "dwellings"). Is this loan HMDA reportable?

Answer:

First, open-end lines of credit are optional reporting. If you report your HELOCs, this is reportable. If you do not, then it is not.

Second, you don't state what the LOC is secured by. If it is dwelling secured and you report open-end lines of credit this loan is reportable. If it is not secured by a dwelling, then you must also have the loan classified as a home improvement loan for it to be reportable.

First published on BankersOnline.com 5/22/06