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#1324783 - 01/14/10 06:45 PM Ag purpose loan-HMDA reportable?
johnsbb Offline
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Joined: Apr 2006
Posts: 30
Our Bank will have to report HMDA data beginning 2010. I have application for a refi of a 9,000 acre ranch which has my borrowers SFR on it. He runs a 2000 head cow calf operation on the ranch. Is it HMDA reportable?

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#1324859 - 01/14/10 07:31 PM Re: Ag purpose loan-HMDA reportable? johnsbb
hmdagal Offline
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hmdagal
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Posts: 3,841
Yes - refis of ag loans don't fall under the same exclusion that purchases do. If there is a dwelling, it's reportable.

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#1324863 - 01/14/10 07:36 PM Re: Ag purpose loan-HMDA reportable? hmdagal
#12 Offline
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fwiw, I agree with hmdagal. As long as the old loan and new loan are both secured by a dwelling, it's a reportable refinance.
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#1325069 - 01/14/10 11:01 PM Re: Ag purpose loan-HMDA reportable? #12
johnsbb Offline
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Joined: Apr 2006
Posts: 30
Thank you both for the help.

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#1508435 - 02/10/11 09:55 PM Re: Ag purpose loan-HMDA reportable? johnsbb
Glo Offline
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Joined: Jul 2005
Posts: 394
Arkansas
What if there is a 76 acre horse farm to PURCHASE, but also has the primary dwelling of the owner of this farm on it? Could this still be HMDA if it's over 25 acres of farm land? Because of the dwelling on the land, it couldn't be CRA, or could it?

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#1508442 - 02/10/11 09:58 PM Re: Ag purpose loan-HMDA reportable? Glo
raitchjay Offline
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OK
However you interpret the "agricultural exemption" language of Reg. C, i think you'd be safe exempting this from HMDA, either from the 25 acre exemption in RESPA referenced by Reg. C, or by the fact that (i'm assuming) the "horse farm" part of the purchase would cause the entire transaction to meet the agricultural exemption. FWIW (and i know there are people who disagree), i would exempt this for the fact that it is a purchase transaction involving over 25 acres.
Last edited by raitchjay; 02/10/11 09:59 PM.
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#1508443 - 02/10/11 10:00 PM Re: Ag purpose loan-HMDA reportable? raitchjay
Glo Offline
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Joined: Jul 2005
Posts: 394
Arkansas
I was thinking the same thing, but just wanted to make sure. Wonder about the CRA part? Would I need to post this on the CRA forum to get a definite answer?

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#1508445 - 02/10/11 10:01 PM Re: Ag purpose loan-HMDA reportable? Glo
raitchjay Offline
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Joined: Oct 2009
Posts: 9,104
OK
You'll probably get an answer here, but it might take a little while. Sorry....can't help you with the CRA part as we do not have to report for CRA.
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#1508446 - 02/10/11 10:03 PM Re: Ag purpose loan-HMDA reportable? raitchjay
Glo Offline
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Joined: Jul 2005
Posts: 394
Arkansas
I will do that! Thanks so much for your help!

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