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ECOA Valuation – Mixed Use Property

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  • March 20, 2014 at 9:55 pm EDT #5631
    rcooper
    Member

    A question we received from a member:

    Do the ECOA appraisal rules apply to mixed-use property that is both business and residential?

    The loan in question is a commercial loan and I understand that 1002.14 applies to both consumer and business purpose loans. To my way of thinking, because it is partly residential, there is no exemption for mixed use.
    Your thoughts?

    March 20, 2014 at 9:56 pm EDT #5632
    rcooper
    Member

    In my opinion, if the property securing the loan meets that definition of a dwelling in 1002.14(b)(2), even though it may also be used for business purposes, the ECOA valuation rules will apply.

    March 26, 2014 at 11:04 am EDT #5650
    MarieR
    Member

    Just to add to this. We had the same question so I contacted the CFPB and they agreed that if there were 1-4 dwellings, even if there was retail space, then the ECOA valuation rules apply.

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