Customer purchased a rental property in January, 2005 and secured it by his farm machinery. In July, 2005, we re-wrote the balance into a fixed rate mortgage loan using the rental home as collateral. Is this HMDA reportable? I don't belive so, as it is not a refinance as we did not use a mortgage on the property on the original loan, and it's not a purchase as it was bought in January, and not with the loan proceeds.

You are correct in your analysis, in my opinion. This is not HMDA reportable for the reasons you cite.

I concur.