If you have a purchase of land with a single family residence and the residence is uninhabitable, is it HMDA reportable? Also, if they plan to renovate or replace the structure within the next year and that is stated in file documentation this would make it HMDA reportable. Correct?
Yes. It is still, although uninhabitable, a "dwelling" for purposes of Reg. C because it is a residential structure. Therefore, it would be reportable.
For reference, see:
12 CFR § 1003.2(j):
"Home purchase loan means a closed-end mortgage loan or an open-end line of credit that is for the purpose, in whole or in part, of purchasing a dwelling."
12 CFR § 1003.2(f):
"Dwelling means a residential structure, whether or not attached to real property. The term includes but is not limited to a detached home, an individual condominium or cooperative unit, a manufactured home or other factory-built home, or a multifamily residential structure or community."
And, in response to the second part of the question - Because it is already reportable, the habitability really has no bearing. The loan is technically a home purchase loan when the loan was made.
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