How do I report the following: Customer has a construction loan to build duplex. We are paying 1/2 of the loan off, adding in another loan payoff for vacant land (located elsewhere) to make the total of one loan, secured by the duplex and lot. With another loan, same day, we are paying the other 1/2 of the const loan, adding another vacant land loan (secured by a house and lot), making up yet another loan for the day (2 total). Are both these loans HMDA? The thing throwing me off is paying off 1/2 of a construction loan making up two loans. We are not actually replacing a note with just paying off 1/2. What is the opinion of the masses?

You are converting a construction loan into permanent financing via 2 loans. You report both loans as a purchase.

I just looked over this file again and the second loan is included in a 1 year loc to finish construction on another house and lot. What now?

Report the one loan as a purchase, the second loan is a new construction loan so it would be exempt from reporting until it is converted to permanent financing.