I am reviewing a file that is renewing an original loan that was made for the purpose of buying a 54 acre farm (land only) and paying off the 1st mortgage of their home at a different location. The memo in file states that the renewal for this loan is for 12 months interest only with 1 balloon payment at the end. The lender states that the loan will be paid off with the proceeds of selling the primary dwelling, or if they do not take out a construction loan to build on farmage, then the balance will be amoritized. My question is it HMDA reportable?