Reporting Single property w/Multiple Buildings that are both Commercial and Residential

Reporting Single property w/Multiple Buildings that are both Commercial and Residential

 

Issue: Commercial loan to purchase a piece of property that contains several buildings; collateral is the property and all improvements (buildings). Some of the buildings are commercial/retail purpose, e.g. motel, radio station. Some of the buildings are residential, e.g. apartment buildings,a 1-4 single family dwelling. The HMDA Getting it Right Guide provides some guidance on "mixed use" properties, but seemingly indicates that "properties" means a single building. Do the GIR mxed-use standards apply in this case when there are multiple buildings that are the subject of the loan and that are the collateral and would you then look to square footage, income generation, value, etc. to determine if the loan is more a CRA small business loan or if it is subject to HMDA reporting? Responses to other compliance message boards are mixed. Some say they do. Others say they do not and any time a dwelling is being purchased (refi or home imp) and held as collateral, the loan is subject to HMDA reporting, regardless if other commercial/retail buildings are also the subject of and held on the loan. Your thoughts?

 
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