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Commercial Loan HMDA- Primary Agricultural?

I'm trying to determine if this commercial loan is HMDA reportable. The borrower is purchasing 295 acres. This mostly vacant land is used primarily for hunting however, there are two dwellings on the property. My question is, can this property be considered primarily agricultural? Referring to Reg. Z guidance on what is considered agricultural, fishing would fit this category but there is no mention of hunting. I wanted to get other opinions as we are leaning towards this being reportable.

by John Burnett:

I'd say it's reportable as a commercial dwelling-purchase loan.


by David Dickinson:

I agree. Just because you have a large amount of land (295 acres) doesn't mean it is used agricultural purposes. If it's used for hunting, that is not an agricultural purpose.

First published on 05/19/2019

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