HMDA Question

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    • If we are making a loan in the name of a company for the purpose of purchasing investment/rental property ….but the loan is not secured by the property being purchased… but by the principal dwelling of one of the owners of the business…..would we report the property as owner-occupied or not for HMDA?

    • What about if the loan is in the name of an individual….but same scenario….business purpose to purchase investment property…..but secured by the principal residence of the individual. Do we report as owner-occupied or not?

    The instructions for completion in Appendix A say “Indicate whether the property to which the loan or loan application relates is to be owner-occupied as a principal residence by entering the applicable code….”

    In the scenarios I outlined above…….which property is the one “to which the loan or loan application relates”….the one being purchased or the one being used as collateral?

    Also, for clarification…..if the loan is business-purpose…..

    • If the borrower is a natural person, we report his ethnicity, race & sex
    • if the borrower is a business entity, we used the appropriate code for NA for ethnicity, race & sex

    Is that correct?

    Thanks so much in advance for any help.


    You report the occupancy of the property that you geocode. For Purchase and refinance use the collateral property. For home improvement, use the property to be improved.

    For businesses, you report Ethniticy (4) Not Applicable; Race (7) Not Applicable; and Sex (4) Not Applicable.


    I agree with tstrait.

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