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My bank is refinancing a loan secured by 30 condominium units in a reportable transaction under HMDA. The building has 32 units total. For HMDA reporting purposes, should the bank report the total number of units or just the ones refinanced?

My bank is refinancing a loan secured by 30 condominium units in a reportable transaction under the Home Mortgage Disclosure Act (HMDA.) The building has 32 units total. For HMDA reporting purposes, should the bank report the total number of units (i.e., 32) or just the ones refinanced (i.e., 30)?

The bank should report the number of units securing the refinancing loan. See Comment 3 to §1003.4(a)(31) of Regulation C (HMDA):

Condominium and cooperative projects. For a covered loan secured by a condominium or cooperative property, the financial institution reports the total number of individual dwelling units securing the covered loan or proposed to secure the covered loan in the case of an application. For example…:

ii. Assume that a covered loan is secured by 30 individual dwelling units in a condominium property that contains 100 individual dwelling units and that the loan is not exempt from Regulation C under § 1003.3(c)(3). The financial institution reports 30 individual dwelling units.

(November 2018)

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