Chelsea C, I believe I see you point and I think this might be reportable.
I agree with David that if there was also a dwelling on the land, this would be exempt. However, you specifically said this:
I have a LO working through a loan that is for the purchase of a 1-4 family investment property primarily secured by tillable bare Ag land...If it's even partially secured by a dwelling and no other exemptions apply, it would be HMDA reportable correct?
This situation is different than having two dwellings where one is on ag land (which is David's example). Your's (at least your
last question/scenario which I quoted from your OP) appears to be a situation where the land is "bare" AND the dwelling is completely separate from the land (and the purpose is not ag).
As a reminder, the ag exemption is a two part test: 1) The exemption applies if the "funds will be used
primarily for agricultural purposes", or 2) "if the loan or line of credit is secured by a dwelling
that is located on real property that is used primarily for agricultural purposes (e.g., a farm)." Unless I am misunderstanding something (and I admit I may not have all information), it appears that 1) your funds will NOT be used primarily for ag purposes (as you appear to state the purpose is to purchase a 1-4 family investment property) and 2) the loan is NOT secured by a dwelling located
on real property used for ag purposes (as you said this is bare land).
Therefore, I don't seeing this specific situation meeting either part of the two-part agricultural test, and thus IMHO this would be reportable (unless, of course, there is additional information I am not aware of that would make the purpose of the funds to be used for ag purposes).