We are NOT currently HMDA reportable but I have a question regarding the collection of information.....

We had a loan that started out as a Home Equity collateralized by a large amount of acreage where the proceeds would be used to purchase a second home that the bank would not be holding as collateral. A few weeks after the LE was issued the purchase fell through and the applicant found another property to purchase for even more money. The Loan Officer didn't think there would be enough equity to cover the new purchase amount so he decided to collateralize the acreage and the new home changing our loan type to a Purchase. The appraisal for the acreage came in two weeks later showing plenty of equity so the loan was changed back to a Home Equity with only the land being held as collateral.

Should we have collected a Government Monitoring Form?

Thank you in advance!

No. The purchase was for a second home, not the primary residence, and your FI is not subject to the collection requirements of HMDA.