Reporting property location when multiple properties

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Question:

If I have a loan secured by four properties, which geocode do I use for HMDA reporting?

Answer:

by John Burnett:

Regulation C section 1002.4(a)(9), official interpretation 4(a)(9)-2 (Multiple properties with more than one property taken as security) has your answer. You pick one of the four properties that contains a dwelling. You do not report information about the other properties. You also report information on the one property you selected for other entries in the HMDA LAR, including entries for 4(a)(5) (Construction method for the dwelling), (4)(a)(6) (Principal residence/second residence/investment property), (4)(a)(14) (lien status), (4)(a)(29) (Manufactured home), and (4)(a)(30) (Manufactured home - land owned or leased).

Answer:

by Dan Persfull:

We don't have this happen often but when it does we check the census tract information and choose the property that is in a LMI census tract if applicable. Helps with CRA.