Need your expertise please. We have a commercial loan that is for the purchase of 67 acres farm & pasture land, which is the predominant use of the property. There is also a home on the property.

I know that vacant land would not typically be reportable for small business, but would I report it as a small farm loan due to the agricultural use? Or do I need to report for HMDA because there is a residence on the property?

Any advice is appreciated!

I would report this as a small farm loan, assuming the amount at origination was $500,000 or less.

When you say this is for a commercial purpose, I assume you deemed this an agricultural related loan. It would not be HMDA reportable.

Official Interpretation
Paragraph 3(c)(9)
1. Loan or line of credit used primarily for agricultural purposes. Section 1003.3(c)(9) provides that an institution does not report a closed-end mortgage loan or an open-end line of credit used primarily for agricultural purposes. A loan or line of credit is used primarily for agricultural purposes if its funds will be used primarily for agricultural purposes, or if the loan or line of credit is secured by a dwelling that is located on real property that is used primarily for agricultural purposes (e.g., a farm).

Thank you so much for your feedback!

or if the loan or line of credit is secured by a dwelling that is located on real property that is used primarily for agricultural purposes (e.g., a farm).

Just a point of interest. Regardless of the loans purpose if the loan is secured by property used primarily for agricultural purposes the loan is exempt from HMDA reporting.