we do many many revolving lines for our rental property owners (we are college town and military town = lots of rentals)

It is not uncommon for a borrower to come for a line using several of his rentals as collateral, since we are adequately secured we don't really care what he is doing with the money - vacation, buy a truck etc.

on our credit application he lists that he may buy more rentals but who knows.

does the fact that he puts he may buy additional rentals on the application make this a HMDA purchase.

Paragraph 4(a)(3)

1. Purpose—statement of applicant. A financial institution may rely on the oral or written statement of an applicant regarding the proposed use of covered loan proceeds. For example, a lender could use a check-box or a purpose line on a loan application to determine whether the applicant intends to use covered loan proceeds for home improvement purposes. If an applicant provides no statement as to the proposed use of covered loan proceeds and the covered loan is not a home purchase loan, cash-out refinancing, or refinancing, a financial institution reports the covered loan as for a purpose other than home purchase, home improvement, refinancing, or cash-out refinancing for purposes of § 1003.4(a)(3).