When multiple properties are securing a HMDA loan and the property values of all the properties securing the loan were relied on in making the credit decision,the property value reported should be the total property value of all the properties securing the loan, not just the property value of the single property being reported as required by 1003.4(a)(9), correct?
Property value is discussed in Section 1003.4(a)(28). Neither the regulation nor the Commentary for this section mentions the possibility of collateral other than . However for the property value used in the loan-to-value ratio, discussed in section 1003.4(a)(24), the Commentary states, “The property used in the combined loan-to-value ratio calculation does not need to be the property identified in § 1003.4(a)(9) and may include more than one property and non-real property.” It would be helpful to have the same discussion in both sections or at least to have a cross reference between the two sections. Section 1003.4(a)(28) states that the number reported is the value of the property securing the covered loan or, in the case of an application, proposed to secure the covered loan relied on in making the credit decision. If you rely on the value of the automobile, in addition to the value of the other collateral, then presumably you should report that amount.