We have trouble from time to time deciding whether a loan qualifies as a home improvement loan for HMDA reporting purposes. Getting It Right says the loan is for home improvements if its purpose is to improve, rehabilitate, etc. a dwelling or the real property on which a dwelling is located and also the loan has to be classified as home improvement on the Bank's books. We struggle with what is considered an improvement to the real property. Some of the scenarios we have had recently which we have not been sure as to whether they are HMDA reportable are ; a loan for the purpose of purchasing a swimming pool, a loan to construct a garage, a loan to make improvements to a barn. In all these scenarios there is a dwelling located on the real property. Does anyone know I set rule to follow in determining when a loan would act to improve the real property on which a dwelling is located for HMDA reporting purposes?

It can be challenging!! We don't have a set of rules - we do release HMDA Interpretions for situations not directly covered in the regulation for areas that are responsible for reviewing the HMDA data. This has helped and you may want to discuss some particular situations with your regulator. Reg C commentary indicates the following:
Inprovements to real property: Home improvements both to a dwelling and to the real property on which the dwelling is located (for example, installation of a swimming pool, construction of a garage, or landscapping). Your example of the pool and garage are definitely HMDA reportable. If it adds value to the dwelling is another good rule to go by.

The commentary to Reg C provides guidance in this area.

2(f) Home-improvement loan.
5. Improvements to real property. Home improvements include improvements both to a dwelling and to the real property on which the dwelling is located (for example, installation of a swimming pool, construction of a garage, or landscaping). (Appendix A of this part, Paragraphs IV. and V.A.5. Code 2.)

"a loan for the purpose of purchasing a swimming pool,
Is this swimming pool part of the dwelling or something that will move with the owners if they sale the home? If it goes with the borrowers, this is not home improvement anymore than a car, appliance, etc. If it is a permanent attachment, it is HMDA reportable.

a loan to construct a garage,
Report as home improvement for HMDA.

a loan to make improvements to a barn.
Report as home improvement for HMDA.