When reporting your HMDA data in 2018, you will now have to report the total number of individual dwelling units for the property that is securing the loan. This data point will always be answered with a number as this is one of the few data points where “not applicable” cannot be reported. When you are dealing with an application that did not end in origination, then the institution should rely on the best information that was available at the time action was taken.
When the loan is secured by a manufactured home community, the data point should include the total number of manufactured home sites that can be occupied. It does not matter if the units are already occupied when you are reporting this data point. When you are reporting on a loan that is secured by only one manufactured home and it is located in a manufactured home community, then this data point should be listed as being “1”.
If the loan is secured by a condominium, then the total number of individual units should be reported on your HMDA LAR. If such things such as manager apartments, vehicle pads, site-built homes, or other rental spaces are considered under the financial institutions underwriting guidelines, then they should also be included in the total of units.
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.