I know we've beaten this topic to death, but I'm a little stumped on this particular loan. It is for the purchase of a full scale poultry facility (227 acres) that just happens to include a rental house. The amount is $585,000, so I can't report it for small farm - but I was trying to decide whether or not it truly is HMDA reportable. I know I have the choice (25 acre exemption, yada yada), but I really feel like the preponderance of purpose is agricultural and the rental house is incidental. Any guidance???

GIR says that you do not report transactions involving the purchase of property that is primarily for agricultural purposes, even if it includes a dwelling. So, no HMDA and no small farm reporting on this one.

Thanks! That's the way I was leaning but I hated to totally lose this to the land of non-reportables...

It's a decent sized loan in a moderate income area.

Would this deal have any possibility of qualifying as a CD loan? Does it promote "economic development" as defined in the reg?

I thought about that.
It's the purchase of an existing business - no new jobs, no additional stability, no influx of revenue, etc. But if you have any ideas on how to work it as CD, I'm all ears!

Sounds like you've covered all of the angles I would've explored.

Oh well...

Thanks anyway!