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How broad should the home improvement definition be applied for HMDA reportability and loan purpose? The definition includes dwelling secured loans to repair, rehabilitate, remodel, or improve the dwelling or real property. Would maintenance be included in that definition? Home maintenance can mean a lot of things, such as painting, changing HVAC unit filters, deep/steam cleaning carpet as well as other things. Is that considered a repair? If maintenance is delayed it can become a repair. Some maintenance such as changing paint colors could be considered a remodel to update a home to improve the value. Would these types of maintenance be considered home improvement?
Also, if the consumer declares a HMDA reportable dwelling secured loan as for the purpose of future maintenance, is that specific enough to support the home improvement purpose code? For a 10 year consumer HELOC, a declaration of maintenance can mean lots of things over time. Is it reasonable to conclude that the home maintenance purpose is home improvement for HMDA?
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