I am bringing back a horse that's long been dead, but not kicked in quite some time. All the past threads I've found on this topic are quite old so I thought I would start it up again.

Refinance of a small farm loan that has a dwelling on it. Certainly HMDA reportable as it is a refi of a dwelling.

Certainly a small farm loan, the loan is coded as such on the call report and the purpose of the loan is for AG improvements.

Do we double count these? I small farm somehow trumped by HMDA?

I am aware the only loans that you are supposed to double count are multi-family loans with a CD purpose. There just isn't any clarification about the small farm loans with dwellings that I'm aware of.

Does anyone have anything new on this?

I was searching for an answer to this same question. Can anybody please respond? Do we double report or only report as HMDA?

You "double" count them. Check out .22(a)(2)-7 in the CRA Q&A.

§ll.22(a)(2)—7: How are
refinancings of small business loans,
which are secured by a one-to-four
family residence and that have been
reported under HMDA as a refinancing,
evaluated under CRA?
A7. For banks subject to the Call
Report instructions: A loan of $1 million
or less with a business purpose that is
secured by a one-to-four family
residence is considered a small business
loan for CRA purposes only if the
security interest in the residential
property was taken as an abundance of
caution and where the terms have not
been made more favorable than they
would have been in the absence of the
lien. (See Call Report Glossary
definition of ‘‘Loan Secured by Real
Estate.’’) If this same loan is refinanced
and the new loan is also secured by a
one-to-four family residence, but only
through an abundance of caution, this
loan is reported not only as a
refinancing under HMDA, but also as a
small business loan under CRA. (Note
that small farm loans are similarly
treated.)
It is not anticipated that ‘‘doublereported’’
loans will be so numerous as
to affect the typical institution’s CRA
rating. In the event that an institution
reports a significant number or amount
of loans as both home mortgage and
small business loans, examiners will
consider that overlap in evaluating the
institution’s performance and generally
will consider the ‘‘double-reported’’
loans as small business loans for CRA
consideration.

HMDA is a mess!

Thank you! And I agree, HMDA is challenging!!

The way the call report works, farmland with a dwelling (with any improvements) is reported under loans secured by farmland and not under loans secured by 1-4 family residence. So if your loan is reported as secured by farmland, it is a small farm loan even if HMDA was triggered. For refis, you can always double report even if small business (whether type 1 - primarily secured by residential real estate - or type 3 - less than 50% secured by residential real estate.)

Loans secured by 1-4 family residential real estate excludes farm property.

The difference in small business loans secured by residential real estate is caused by the call report - those loans are reported in the loans secured by residential real estate section, which takes it out of small business reporting. That is why we have "CRA Type 3 - Other Small Business" and the carve out for small business loans trapped by the broad HMDA refi rule.

So we shouldn't double report them?

There was a thread earlier this year that led me to believe that they should be double reported.

I have a few of those on my LAR that I just sent off.

I thought that the HMDA farm exemption was only used for purchases but would not be exempt for a refi.

I AM COMPLETELY CONFUSED

oh oh....

You're fine Boatn. You DO double report and the farm exemption is only good for a purchase, not a refi.