[Anonymous]

We’re taking collateral on a single condo and a small apartment complex. How would you classify the collateral type for HMDA purposes? I’ve looked in the Guide to Getting it Right already and it really doesn’t mention anything about this. Any thoughts?

[jholzknecht]

The following information from the Commentary to Regulation C indicates which property is reported when the loan involves multiple properties. Your should report property type for the property being reported.

4(a)(9) Property location.
1. Property location—multiple properties (home improvement/ refinance of home improvement). For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/LAR (with unique identifiers) and allocating the loan amount among the properties.
2. Property location—multiple properties (home purchase/refinance of home purchase). For a home purchase loan, an institution reports the property taken as security. If an institution takes more than one property as security, the institution reports the location of the property being purchased if there is just one. If the loan is to purchase multiple properties and is secured by multiple properties, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/ LAR (with unique identifiers) and allocating the loan amount among the properties.

[Anonymous]

Thank you, I forgot about that. I’m used to multiple pieces of property being the same type of dwellings. 😉

[Author]

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