Q: Are investment properties with a loan purpose of Code 4 HMDA reportable?
A: Code 4 for “Loan Purpose” corresponds to “Other Purpose.” You do not report “Other” purpose loans that are “business purpose.”
Reference:
Code 4—Other purpose
Data Point “(5) Loan Purpose, Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2020: https://files.consumerfinance.gov/f/documents/cfpb_2020-reportable-hmda-data.pdf
The requirements of this part do not apply to: . . . (10) A closed-end mortgage loan or open-end line of credit that is or will be made primarily for a business or commercial purpose, unless the closed-end mortgage loan or open-end line of credit is a home improvement loan under § 1003.2(i), a home purchase loan under § 1003.2(j), or a refinancing under § 1003.2(p);”
Not a member? Learn more about membership with Compliance Alliance by attending one of our live demos:
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.comand ask for our Membership Team. For timely compliance updates and resources, subscribe to Bankers Alliance’s email newsletters.