Q. Heather, I have a HMDA (Home Mortgage Disclosure Act) Question. What if we have a member that is using a residential investment property for collateral to buy another residential investment property. Since the funds were used for a residential purchase would we need to report it for HMDA?

A. Really great question. For business loans, HMDA is triggered if the purpose of the loan is to purchase a dwelling and the loan is secured by a dwelling.  It doesn’t have to be the same dwelling. So in this example, the loan would be HMDA reportable.