I just looked at this HMDA Input Reporting Worksheet on BOL and I have a question. The worksheet says "Excluded loan applications: If any of these questions are marked “yes”, this application is not HMDA reportable," and one of the questions is, "Is this an application primarily for business/agricultural purposes? (See HMDA Criteria for refinances.)." Does anyone know why a business/agricultural loan app would be excluded from HMDA?

I believe that's an outdated worksheet.

I don't think so. The reporting requirements haven't changed since 2004. I'm not aware that ag or business loans were ever excluded. I'm thinking maybe it means if, for example, the application was to purchase a working farm and there happened to be a dwelling on the property. But, I'm just not sure because of the way it reads.

That's an internal form designed for our loan officers to use. If you will note it advises the loan officers to refer to the "HMDA Criteria" for that line item.

In the criteria sheet the definition of a home purchase, home improvement and refinancing is given with examples of how they apply along with other instructional information for completing the form.

Due to our make up most of our loan officers are both commercial and consumer loan officers and that was the basis for the business loan reference.

A business purpose loan secured by an equity lien in a dwelling is not reportable unless it meets one of the definitions outlined in the criteria. The same holds true for agricultural purpose loans and in their case they are exempt from the home purchase category.

If you will also notice under the "Type of Purchaser of Loans" there are only two categories. The only ones that apply to us.

This form was provided as a tool to be modified as needed to fit your specific processing needs so you didn't have to start from scratch. You could eliminate that entire section of the from if you wanted.


FYI. On our updated version that line now reads:

Is this an application primarily for business (other than covered loans)/agricultural purposes? (See HMDA Criteria for refinances.)

If the (other than covered loans) was on the original I'm sure it may have been clearer as to the intent of that line item.

Dan, thanks so much for clarifying. I knew that the form was based on your bank's procedures but I just couldn't find the basis for a business-purpose exemption (which is what I thought that line meant). Your explanation makes sense and again I thank you for taking the time to explain it.