Banker's Compliance Consulting Blog

HMDA Dwelling: Assisted Living vs. Nursing Homes

Written by David Dickinson | Feb 9, 2026 7:52:40 PM

In order for an application to be HMDA-reportable, it mustbe secured by a dwelling. HMDA defines adwelling as, …a residential structure, whether or not attached to realproperty… but there are a lot of exceptions. For instance, a “transitory residence” is notconsidered a dwelling for HMDA purposes. Transitory residences include things … such as hotels,hospitals, college dormitories, andrecreational vehicle parks, and structures originally designed as dwellings butused exclusively for commercial purposes. Thiscan get a little confusing when a loan is going to be secured by an assistedliving type facility or nursing home. Are those dwellings or not?

David explains more in the video.




Published
2026/02/09