[srhodes]

We are taking what we consider an apartment complex as collateral. The apartment complex is actually four separate duplexes that are all located on the same property and owned by the same borrower. Our appraisal describes the collateral as an 8-unit apartment complex. The confusion is if we should report this as a ‘Multi-family’ dwelling due to the fact that each actual structure is a duplex.

[jholzknecht]

Comment 2(n) – 3, from the definition section of Regulation C distinguishes between multiple dwellings that are not multi-family on one property versus multiple dwellings that are not multi-family on multiple properties. The former is considered multi-family, the later is not.

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