[Yosimar Huerta]

We have a FHA loan secured by a single-family dwelling that includes a detached Accessory Dwelling Unit (ADU). According to the appraisal, the ADU consists of 2 bedrooms, a living room, a kitchen, and a bathroom. We believe the ADU qualifies as a separate dwelling unit for HMDA reporting purposes. However, our Mortgage team asserts that it should be considered as one unit per the FHA Handbook.

Based on this, we understand that the FHA would consider this property as one unit. However, for HMDA reporting purposes, we believe it should be reported as 2 units. I have been unable to find any section on the regulation indicating whether the FHA Handbook can be used to determine the unit number for HMDA reporting purposes. I am just trying to see if we should be reporting this property as 2 or 1. Thank you.

Topic

[Kimberly Boatwright, CAMS, CRCM]

For HMDA transactions you would only report number of units for multi-family properties. Multi-family is described as more than 4. This would not qualify as muti-family by way of definitions based on the situation described in the question.

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