How to Report Commercial Buildings on LAR

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Question:

I have a loan for 3.7 million secured by 2 commercial buildings and (8) 4-plexes. We split our entries on the LAR. Would I divide the 3.7 million by 8 (the dwellings)and report as 8 entries on the LAR?

Answer:

You can, but I wouldn't. It's one loan, so you can report it as one entry on the LAR. Here's the regulatory guidance on this topic:

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

b. 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 5/21/12