HMDA and Loans Secured by Multiple Properties

Issue/Inquiry

The Bank has made a loan that is secured by 17 residential properties around the state, which have a total of 37 units. How should this loan be reported on the Home Mortgage Disclosure Act (“HMDA”) Loan/Application Register (“LAR”)?

Response Summary

The Bank should report the loan in one entry on the HMDA LAR and identify one property as securing the loan. Any additional information required by the HMDA LAR for the property securing the loan will relate only to that property identified.

Response Detail

The data points reported on the HMDA LAR include, but are not limited to, the following concerning the location of the property securing the covered loan:

• Property address
• Whether the property is located in a Metropolitan Statistical Area (“MSA”) or Metropolitan Division (“MD”) in which the financial institution has a home or branch office

Banks and savings associations that are required to report data on small business, small farm, and community development lending under regulations that implement the Community Reinvestment Act of 1977 must also collect the information required for property located outside MSAs and MDs in which the institution has a home or branch office, or outside any MSA. 12 CFR 1003.4(a)(9).

If more than one property is taken as security for a single covered loan, a financial institution will report the covered loan in a single entry on its HMDA LAR and provide the required location information for just one of the properties taken as security that contains a dwelling. A financial institution does not report information about the other properties taken as security.

If an institution is required to report additional information about the property securing the loan, it will report the information pertaining to the one property that is identified in the location entry. In this case, if the property identified on the HMDA LAR as the property securing the loan is a multi-family property, the Bank would provide information such as the number of dwelling units pertaining to that multi-family property or the number of dwelling units that are income-limited under federal or state law or local housing ordinances. Official Interpretations, 1003.4(a)(9) – 2.      

This response is for informational purposes only and is not legal advice.

This entry was posted on Tuesday, October 15th, 2019 at 6:00 am.