Q: We have a mobile-home-secured loan that does not involve real property. Most of the funds will be used for debt consolidation; however, a small portion will also be used for home improvement purposes. The loan is not coded as a home improvement loan. Should this loan be reported?
A: Yes. Regulation C has two standards for reporting home improvement loans. Under §203.2(g)(1), a dwelling-secured loan made for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located is considered a home improvement loan. Under this standard, a loan does not have to be classified as home improvement to be covered. Conversely, under §203.2(g)(2), a non-dwelling-secured loan for the same purposes stated above is a HMDA-reportable loan if it is classified by the financial institution as a home improvement loan. In this example, the loan would be reported because it is: (1) dwelling secured (mobile home) and (2) made in part for home improvement purposes.
This can be found in - HMDA FAQ#5 of the FAQs. The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/