[droessler]

A property is purchased by a Trustee for an individual(consumer). The ground floor is a business run by the Trustee, and the Trustee is renting out the upstairs as a residence to a third party. How should we characterize this for HMDA purposes.

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[rcooper]

From page D-5 of HMDA Getting it Right (https://www.ffiec.gov/hmda/pdf/2013guide.pdf):
2. Mixed-use property. A dwelling-secured loan to purchase property used primarily for residential purposes (for example, an apartment building containing a convenience store) is a home purchase loan. An institution may use any reasonable standard to determine the primary use of the property, such as by square footage or by the income generated. An institution may select the standard to apply on a case-by-case basis.

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