HMDA Reportable- Temporary Finance -Business Purpose Loan

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    I have a company that requested a loan (2nd Lien) to finish converting a dwelling into multiple offices and is being secured by the same property. After the company converts the dwelling into offices, the company will be using the property as their corporate office, and they will be requesting a zoning change from SF-3 to MU to allow the property to be used as an office. Also, the Lender gave them 24-month/interest only loan to complete the renovations. Would this loan be considered HMDA reportable loan?

    • This topic was modified 5 months, 2 weeks ago by Cescamilla.

    No, this is not a HMDA reportable loan. It includes no residential structure.

    Business Purpose Paragraph 3(c)(10)-1
    If an institution determines that a closed-end mortgage loan or an open-end line of credit primarily is for a business or commercial purpose, then the loan or line of credit is a covered loan only if it is:
    • A home improvement loan under § 1003.2(i).
    • A home purchase loan under § 1003.2(j); or
    • A refinancing under § 1003.2(p).

    Dwelling – Exclusions Paragraph 2(f)-3

    Recreational vehicles, including boats, campers, travel trailers, and park model recreational vehicles, are not considered dwellings for purposes of § 1003.2(f), regardless of whether they are used as residences.
    • Houseboats, floating homes, and mobile homes constructed before June 15, 1976, are also excluded, regardless of whether they are used as residences.
    • Also excluded are transitory residences such as hotels, hospitals, college dormitories, and recreational vehicle parks, and structures originally designed as dwellings but used exclusively for commercial purposes, such as homes converted to daycare facilities or professional offices.

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