Unsecured to Replace Existing Damaged Pool-HMDA?

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Question:

Is an unsecured loan for an above ground swimming pool, to replace an existing pool damaged by weather considered HMDA? I know it would be if a pool had not already been in it's place, but being as there was once one existing there, I am little hazy on it.

Answer:

Repairs and replacements do qualify as home improvements. Whether this loan is HMDA reportable depends upon the bank's classification of improvement loans not secired by a dwelling.

1003.1

Home improvement loan means:

(1) A loan secured by a lien on a dwelling that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located; and

(2) A non-dwelling secured loan that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located, and that is classified by the financial institution as a home improvement loan.