We have a loan for purpose of taking a loan out of construction and putting into monthly payments. Construction loan was for purpose of constructing a pole building with concrete floor. The loan officer tells me that there is a house being constructed on property, but it is not complete as yet. It is only framed and boxed. We are not providing financing on house, customer is building as he has the money. Is this HMDA reportable? If so as what since home is not complete, I don't think home improvement.Hope this makes sense, because I am really confused.

it sounds like a construction loan to me and therefore not reportable. the financing sounds like it isn't even for a complete building.

however, i'd be interested to hear others' opinions on the fact that the building is going to be part of a permanent arrangement. i would tend to think this is only something that "sounds" like a construction loan because i am unaware of any requirement to have 100% of the building costs financed to make it HMDA-reportable.

i can see arguments either way on the reportability of this.

laf, you're taking a construction loan to permanent financing, right? If so, we have to look for a different reason to disqualify it from HMDA reporting.

The loan is for the pole barn not the house being constructed. Is the pole barn for business purposes (like farming) or is it for pleasure (parking the owner's cars)?

Either way, at this point I'd say because there is no reportable dwelling on the property, it's not reportable for HMDA.

Someone (Dan ) may step in here and say that because the house is being built, this is a home improvement loan. If so, I'll acquiesce to his guru status.

The question to be answered is there a dwelling located on the property and will the loan be secured by a dwelling or classified as a HI if not dwelling secured?

If the existing structure is still in the course of construction and you are not providing the construction/permanent financing then I would assume your loan is not dwelling secured since a dwelling does not yet exist, therefore you are not improving a dwelling or the real property upon which a dwelling is located.

the way i read laf's post, it seems the only thing that is being financed is the structure (i don't know what "pole building" means and i assumed it was a way of saying the skeleton of the house). but if this is a separate building and nothing on the actual house is being improved (even though the land is) other than what the owner is paying for himself, i dont see this as HMDA reportable.

Pole building/barns are usually utility structures.

I agree. If the house was done, this would be home improvement if secured by the RE the residence is on. If it wasn't, then it would depend on if the bank classified it as HI.

Not to throw a wrench in anything, but I have had a loan on a barn that had a 12x12 "living area" according to the appraisal, which consisted of a kitchenette, bathroom and couch space, and HMDA helpless told me it "although not conventional is considered a dwelling". So does the pole barn have any dwelling type area, such as an apartment upstairs etc.?

About 3 years ago we had a "barn" constructed at a cost of $250,000 and it too had living quarters in it. The "barn" was a horse arena to be used to stall and train thoroughbreds. The living quarters were for the caretaker. I exempted it as a dwelling based on the square footage and income generation.