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For a HMDA related loan secured by a main house and a pool house, would the total units be reported as 1 or 2?
We may need more detail on the pool house arrangement. Is a separate family living in the pool house? Is it rented out? Does it have separate meters for utilities? Does it have all of it’s own appliances, a full bathroom, laundry room, etc.? Basically, what is it’s use and purpose? Is it more used as a separate segregated bedroom, or an entirely independent dwelling as with a duplex or possible guest house situation? AND, how is it platted/zoned with the county?
I am not sure if anyone is living in the pool house. It’s a detached building that is a large room with a kitchen and dining area, full bathroom, and one small room that could be used as a bedroom. There is always a washer/dryer. I don’t think the homeowner has plans to rent it. It’s next to their swimming pool which is located behind their main house.
This appears to be used more as an extension of the home and, at best, transitory in nature (used periodically by visitors/family). I would be more inclined NOT to report it as a separate unit that counts towards the Total Units count. I am sure this pool house is considered to be a part of the main home by the County Appraisal District, and it doesn’t have it’s own utility meters as well. There’s just not enough for me to consider it as a separate unit, at least not currently. I would report just 1 unit for this home, but there may be others with a different opinion. Regardless, be sure to be consistent in whatever approach you choose and be ready to explain.
If multiple properties secure a loan, Regulation C requires in section 1003.4(a)(31) that the number of individual dwelling units related to the property should reflect all the properties that secure the loan. This does not appear to be a separate dwelling. As stated by pparks above, the pool house appears to an extension of the home.
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