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HMDA Occupancy Type

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  • #15995
    TheBank
    Participant

    What occupancy type should be given to a refinance of a principal residence where the loan is in the name of the occupant’s company and signed by the president and secretary of the company which are the occupants?

    Would that be a 3 because the borrower is an entity? OR a 1 because it is technically occupied by the company’s Officers? The certificate of existence shows the registered agent address as that home.

    #15996
    JGo9
    Participant

    If the business is your borrower and their officers are not co-borrowers, then 3 would be the proper way to report the occupancy for the scenario you have described.

    It may feel odd, and it may not make sense, but you talking about bank compliance where common sense does not always apply.

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