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We recently had a HMDA question where the primary borrower was a business and the co-borrower was a natural person. Would we report this loan for HMDA? Assuming all other factors pointed to that the loan should be reported; i.e., a single family dwelling, loan is secured by the dwelling, non-agricultural purpose?
Assuming the loan is otherwise HMDA reportable, the presence of a business as the primary borrower does not disqualify the loan from HMDA reporting. Certain business purpose loans are excluded from HMDA reporting. The Commentary includes guidance on reporting certain fields, such as ethnicity, race and sex, when a applicant is a business entity.
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