[Anonymous]

We are originating a commercial line of credit (LOC) that is unsecured. The purpose of the LOC is for repairs and improvements to rental property. Additionally we include and report home improvement loans on the LAR.

Since the LOC can be used for any repair/improvement to any of their rental properties during the term of the LOC and a particular property is not specified to be improved either at application or closing, what information should be used for property location, property type on the LAR?

Thanks!

[rcooper]

From A Guide to HMDA Reporting: Getting it Right (https://www.ffiec.gov/hmda/pdf/2013guide.pdf)

Paragraph 4(a)(9).
1.
Property location—multiple properties (home improvement/refinance of home improvement). For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/LAR (with unique identifiers) and allocating the loan amount among the properties.

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