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We have a loan for the purpose of purchasing land only (no structure, no intent to build, no repayment using refinance for construction) secured by the land as well as an abundance of caution third lien on the primary residence. For purposes of Reg B collection, would GMI be collectible. Additionally, would we report on the LAR per Reg C or mark all GMI fields as “NA”?
For Reg C – HMDA. If there is no “dwelling” HMDA does not apply. For Reg B collection is based on principal residence dwelling related credit. Since you have chosen to take the principal residence as collateral, the transaction would require both HMDA and Reg B GMI collection. Had you not taken the primary residence as collateral you would not have had any collection requirements for the land only transaction.
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