I have looked high and low for an answer but the regulation and everything else just refers to unimproved property. We have a loan with a purpose of purchasing a lot, which is an improved lot, meaning curb and gutter. Would this loan be HMDA reportable, it is secured by both the customers current primary residence and the new lot. Also, would it matter if they were not going to build on the land for more than two years? Thanks

HMDA covers the purchase, refinance (purchase/improvement) or improvement of a dwelling, or the land on which the dwelling resides. Since there is no dwelling on the lot being purchased, and I assume none of your loan proceeds for the current transaction will be used to construct the new dwelling, HMDA would not apply.

If you want additional comfort in not reporting this loan, consider it a prelude to a construction loan. The government doesn't want the data until a dwelling is involved.

Thanks for the reply. So, there is no difference between unimproved land and improved land and it is therefore not reportable? What about time frames if the customer intends to build primary residence lets say within a year, then would it become reportable. I'm probably crossing the regs together Z and C, Z talks about whether or not a dwelling will be constructed during a year to determine if it will be the primary residence for recission.

Don't use Reg Z to interpret Reg C. Regulations don't necessarily talk to each other, even though the same people write them! HMDA's definitions exist to set criteria for what loans get reported for purposes of analyzing your lending patterns. Z has definitions to set the parameters of consumer protection. Different purposes, different definitions, and more compliance difficulty.

For HMDA purposes, the Fed's concern is at what point they want to hear about the money you are investing in a geographic area. That line is drawn with the house.