[benef005]

Over the past 18+ months, my institution has originated several construction-perm (single closing) for multi-family dwellings which are reportable. A small number of these loans are for off-campus student housing. Given the intended leasing structure, where leases to students are for a room in an apartment unit rather than one lease for the entire unit, should these loans be viewed as transitory and therefore excluded from HMDA reporting? A thought for not applying the exclusions outlined in 12 CFR § 1003.2(f)-3 has been the borrower. The borrowers are for-profit companies who will own/manage these properties. Additionally, there have been no absolute guarantees that a non-student could lease a unit as his or her primary residence.

[rcooper]

If the property is intended to be used as a dormitory, but is not limited to use as a transitory residence I do not think that exclusion would apply.

[Author]

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