We did a loan to purchase land less than 25 acres that has a SFR. The borrowers plan to remove the SFR and build. The appraisal doesn't include the SFR. I believe the SFR isn't structurally sound. Not HMDA reportable? The loan purpose is to purchase the land, not the SFR.

If they plan to raze the dwelling, i wouldn't report....but...you say they plan to remove it and "build". Is your loan financing the construction of a dwelling? With permanent financing?

The loan does not include construction at this time; only the purchase of the land. If not for the existing SFR, I wouldn't even question this but.....

"We did a loan to purchase land less than 25 acres that has a SFR."

How you choose to value this property really isn't a consideration for HMDA.

I agree with Randy. If there's a dwelling, then it's a dwelling. Whether the appraisal gives it any value or not. The appraiser was probably instructed to not value the building since you plan to remove it.

However, is this "SFR" a "dwelling". It is inhabitable? You say it isn't structurally sound. If that's true, you could easily say it's just a building - if no one dwells in it.

It was stated that the intent was to raze the building. I think that's all you need to exclude from HMDA.

Thanks everyone. I appreciate your time.

It was stated that the intent was to raze the building. I think that's all you need to exclude from HMDA.

If it's well documented I would agree for the initial loan, BUT, if for any reason the loan has to be refinanced and the dwelling remains it will have to be reported as a refinance at that time.