HMDA: Mixed-Use Properties
HMDA is all about dwellings. Specifically, dwelling-secured loans where the proceeds will be used to purchase, refinance or improve a dwelling and other consumer purposes. A “dwelling” can be a single-family home, an apartment complex, a mobile home, a rental house, etc. So, what do you do when you have a property that has both dwelling (residential) and commercial (non-residential) space? Or, in other words, a “mixed-use” property. Is it a dwelling for HMDA purposes or a non-dwelling not subject to HMDA?
David explains more in the video.
Video Highlights:
- Whether a property is classified as residential or non-residential for HMDA purposes, the primary purpose of the building should be considered.
- A borrower's statement of intent and/or criteria such as square footage and income per square foot may be used.
- It is important to document your determination in the loan file.
Published
2023/02/10
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.