We have a customer that wants to get an ag loan to build a dairy building onto their property. The loan would be secured by a 2nd lien on their property which includes their house and 20 acres. This is not a home purchase loan which would exclude ag purpose loans. Do home improvement loans have this exemption as well? I know the building is being put on the real property that the dwelling is, but it is for ag purpose.....does that matter?

I know if we were to refinance this loan at anytime, then it would be reportable as a refinance.

Thanks for your help!

Did you try sending this question to HMDA Help - hmdahelp@frb.gov

You can email your question and then keep a copy of their email response in your file to support whether or not you reported the loan.

Are you thinking that a dairy barn will be seen as a home improvement? See "Mixed Use property" on D-5 in the Getting it Right Guide for some help.

I'm with Sage (I think). This is not a home improvement loan. The application is to improve the commercial part of the land that a dwelling is also located. Not HMDA reportable.

David - if we have consistently reported these type of loans as home improvement in the past (with the reasoning that it is improving the real property on which the dwelling is located); would it be better to remain consistent with our reporting, or go back and scrub and change these?

Not David but I can tell you from experience that when we've changed some aspect of reporting we've only done it starting in the current year. I document the reason behind the change and use it for the entire year even if that means I have to backtrack. Examiners have not questioned or made us go back to previous years to resubmit.

Funky: I can't endorse over reporting because that's the way we've always done it. I agree with Truffle that it's best to make changes at the beginning of the year. It's only January. Make the change, remove any on the 2015 LAR that may have been incorrectly reported and document why.