Compliance Q&A: Investment Properties & HMDA

Q: Are investment properties with a loan purpose of Code 4 HMDA reportable?

A: Code 4 for “Loan Purpose” corresponds to “Other Purpose.” You do not report “Other” purpose loans that are “business purpose.”


Code 4—Other purpose

Data Point “(5) Loan Purpose, Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2020:

The requirements of this part do not apply to: . . . (10) A closed-end mortgage loan or open-end line of credit that is or will be made primarily for a business or commercial purpose, unless the closed-end mortgage loan or open-end line of credit is a home improvement loan under § 1003.2(i), a home purchase loan under § 1003.2(j), or a refinancing under § 1003.2(p);”

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