The first step in determining whether an application is HMDA-reportable is determining if the loan is secured by a dwelling. If it is, you then look to whether the application is for a HMDA purpose [purchase, refinance, home improvement or other (aka consumer home-equity)]. The Commentary to §1003.2(f) #3 states that …transitory residences such as hotels, hospitals, college dormitories, and recreational vehicle parks, and structures originally designed as dwellings but used exclusively for commercial purposes… are not dwellings. In light of this, we often get questions about homes used for Airbnb, Vrbo, etc., and whether they qualify as transitory residences.
David explains more in the video.
Published 2026/11/05