I have a first mortgage 1-4 home with 137 acres farmland loan. The affiliate is HMDA reportable, so should I be looking for GMI or HMDA Report? The loan is classified as Non-residential/1st mtg-

OSC to Reg C at 2(h)3. allows an exemption to HMDA reporting for farm loans. But it doesn't look like you have it classified as a farm loan.

If the loan is classified as Agriculture/ Farm Loan and is a purchase, it may be exempt from HMDA/Reg C. Refinance does not have this exemption.

Reg C:Section 1003.2--Definitions -- Home Purchase
3. Farm loan. A loan to purchase property used primarily for agricultural purposes is not a home purchase loan even if the property includes a dwelling. An institution may use any reasonable standard to determine the primary use of the property, such as by reference to the exemption from Regulation X (Real Estate Settlement Procedures, 12 CFR 1024.5(b)(1)) for a loan on property of 25 acres or more. An institution may select the standard to apply on a case- by-case basis.

Ok, that's very informative. Thank you for your help.

As for the GMI concern, there's no exemption in Reg. B for ag. purchases.....you'd need the GMI......assuming the loan was for the purchase or refinance of the borrower's primary residence that is.

Well, now that you mention it, that makes perfect sense. They have this set up as more of a agri/business loan, and the address of the borrower is different from the address on the collateral, so I'm thinking it is not for primary residence. Thanks for all of your help!