Purpose is to purchase a 15 stall horse barn with an 1900 SF single family apartment attached; site is 23 acres. Borrower is a business…not owner occupied. Property zoned agricultural/rural.

Not HMDA reportable?

I'd say not reportable, as the mixed-use test for the horse barn would seem to favor an agricultural purpose.

I had an exact situation a few years ago. A horse trainer built a barn with an indoor arena and a 2 apartments. One for her when she was on the "farm" and the other for the full time care taker. Based on the square footage of the stalls and arena section vs the apartments we did not classify it as a dwelling.