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?

It doesn't sound like it. First, you don't indicate that the new loan will be secured by a dwelling - it looks like it is only secured by the agricultural land. If it is indeed also secured by the dwelling, I would consider it to be temporary financing.

YEs, it is secured by a 1st mtg on both the land and the home. My opinion is that it is temporary financing also, but that is not the opinion of my collegue because it is a renewal of a previous loan and could be amortized.

The loan is not currently amortizing, and the primary source of repayment is the sale of the dwelling. That would be temporary financing.