18 month interest only loan to purchase 290 acres with 3 homes and several horse barns on it. Option for one six-month interest only loan for infrastructure work to be completed and allow for sale of individual lots. Land will be subdivided into 35 acre tracts. Primary source of repayment will be from infrastructure development and subsequent sale of each lot. Is this a HMDA reportable loan as a purchase since the there is no plan to replace the loan with separate permanent financing?

loan to purchase 290 acres with 3 homes

What would exempt it from being a home purchase loan under 1003.2(j)?

The only thing that I can think of that would exempt it would be if there was a plan for permanent financing once the 18 month and optional 6 month extension were completed. Then it could be excluded as temporary financing. Since there is no plan for permanent financing, we will report it as a purchase.