We are trying to re-structure our internal codes and my head is absolutely spinning.

Could someone please remind me what happens on a refi of residence + 25 or more acres farmland? I can't remember if we have to pick HMDA or CRA or if it's both.

Thanks!

I'm going to assume that you know whether or not the loan meets the definition for CRA small farm reporting. Then, your more pressing question is whether it is reportable as a refinance for HMDA. If the property contains a dwelling, then yes, HMDA also.

That's what I'm trying to decide - if it gets double reported or if HMDA trumps CRA.

I believe this is one of those situations where it would be double-counted, but I can't find any documentation to back that. I just seem to remember that the regulators did acknowledge that some loans could be reported for both HMDA and CRA....

Our examiners said you can put it in both places but when they do their reveiw, we have to pick which area we want it counted for the exam.

I'm resurrecting my own dead thread.

Two refinances of 200+ acres working farmland. Only catch is - they both contain the borrower's primary residences as well. I've got them on my HMDA LAR, but am trying to decide whether or not they get double counted for small farm?

I found it..bringing it over! (the answer is yes)