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We have loans to an employer to reimburse them for the purchase of mobile homes to house workers. Each loan is secured by a mobile home. While I know these are transitory circumstances that won’t be reported on the HMDA LAR, what Call Report code would be most appropriate? 1c2a (1-4 family – secured) or 1e2 (non-OOCRE)? I am trying to confirm whether or not there is a case for them to be reported on the CRA LR itself (not just considered separately). Thanks for the feedback…
As discussed in your prior post, it is not clear that the mobile homes are transitory housing. We will have to trust your conclusion on that point.
The two Report of Condition categories are very similar. One distinguishing feature is that 1.e.(2), “Loans secured by other nonfarm nonresidential properties,” are those nonfarm nonresidential property loans where the primary source of repayment is derived from rental income associated with the property (i.e., loans for which 50 percent or more of the source of repayment comes from third party, nonaffiliated, rental income) or the proceeds of the sale, refinancing, or permanent financing of the property. The primary source of loan repayment will determine if the loan is reported under 1.e.(2).
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