We made a loan with the following purpose: Purchase 40 acres of farmland and pay-off an existing loan that was secured by additional farmland that includes the borrower's primary dwelling.

Collateral is as follows: Mortgage on the 2 parcels of farmland (including the borrowers dwelling).

Is this HMDA or CRA (small farm) reportable?

I say yes, it is a HMDA reportable refinance. You had a dwelling secured loan that you are paying off and replacing with another dwelling secured loan. Can't help you with the CRA part.

Thanks raitchjay.

I believe that normally you don't report the loan as both HMDA and CRA, so then I shouldn't report as CRA also.

Here's some info on double reporting for HMDA and Small Farm loans. Search the document using double reporting as the search term.

http://www.fdic.gov/news/news/financial/2005/fil2905a.html


And FWIW I agree the loan you quesiton is a reportable refinancing for HMDA.

I know the general rule is, if a loan is both a purchase and a refinance (which this loan is), then you report it as a purchase.

So while this loan is not a reportable purchase (due to agricultural purpose exemption) it is still reportable as a refinance?

There is no ag exemption for this loan. The purpose of the loan is to purchase 40 acres of farmland and refinance a loan currently secured by farmland with a 1-4 dwelling. Therefore it meets the definition of a refinancing.