Loan Secured by 3 Properties-Which to Report?

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Question:

I have a loan where the purpose is to purchase a residential dwelling. The loan is being secured by three other properties that does not include the property being purchased. Which property do I report on for HMDA?

Answer:

You'll find the answer on page D-12 of the 2010 Getting It Right guide:

2. Property location—multiple properties (home purchase/refinance of home purchase). For a homepurchase 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.[Emphasis added].

First published on BankersOnline.com 2/6/12. Revised 6/19/12 when we were notified of the correct response by a federal agency compliance examiner.