Loan w/ Purpose for Commercial Investments-HMDA?

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Question:

I have a commercial loan with two residential properties, one primary and one rental but the customer owns out right but the is not purchasing, refinancing or using any part of the loan for home improvements. Is this loan HMDA reportable? The purpose is for commercial investments into another business.

Answer:

This loan would not be reportable since it does not meet any HMDA reportable purpose (purchase, home improvement or refinance). Should this loan later be refinanced and again be secured by residential real estate it will be reportable as a refinance at that time.

First published on BankersOnline.com 5/21/12