Purpose of loan is lower monthly payment, the loan will be secured by mobile home and 43 acres so HMDA would not apply since we used the REG X (RESPA rule exemption 25 acres or more)
Correct??????

The exemption is only for purchases. This sounds like a refinance, which would be reportable.

As hmdagal stated, this exemption is only for purchases. But more, the amount of acres isn't really a factor. I grew on a 10 acre hog farm. It was absolutely a farm, but not 25 acres or more. Where I now live, there is a 40 acre piece of land owned by a man from Minneapolis. He hunts deer, ducks, etc., but doesn't farm it. It's really his cabin and hunting land. Just because it's more then 25 acres doesn't make it a farm.