[Mary Beth Devillier]

I have a customer who wants to consolidate debt that is currently in place at my institution. More of the debt was business purpose and secured with commercial properties while the remaining debt was consumer purpose and secured with his primary 1-4 family dwelling. With consolidating all of this debt into one loan and keeping all of the properties as collateral, HMDA will apply, but TRID would not since more of the debt and purpose was individual for business purpose…am I thinking of this the correct way? Now, for number of units to report, I am only including the Residential 1-4 dwelling, right?

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[CParker1]

Hi Mary Beth,
The comments for multiple properties at this link were helpful to me: https://www.consumerfinance.gov/rules-policy/regulations/1003/interp-4/#4-a-9-Interp-1

I believe you report all dwelling units for HMDA. You only need to report one address.

[Author]

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