I am struggling with this loan. The purpose is to purchase timberland. They will also be refinancing their primary that is on 20 acres (don't know what they do with all the acreage. So we have two pieces of collateral but the purpose is for the purchase of the timberland. I can't decide if I can exclude this loan under agri or not. Can I exclude under agri since the purpose is to purchase the timberland which is what I thought we changed to in 2018? But the refinance of their primary as part of the transaction is confusing me.

If the majority of the loan proceeds will be used or an agricultural purpose OR if the land with dwelling(s) securing the loan is used primarily for agricultural purposes, the loan will not be HMDA reportable regardless of loan purpose.

Thank you Dan.