We have an ag refinance with collateral of 160 acres plus a house. The previous loan (closed end, not a line of credit) with the same borrower had the collateral of 160 acres plus a house. A new loan by same borrower replacing old loan, house and 160 acres collateral on both loans. I say HMDA reportable as refinance, my boss says not. Boss calls OCC. OCC regulator says not. Report or not?

It's reportable. Here's a thread with more information and discussion.