As President of the I Hate HMDA Club, I now call the meeting to order:

Question - Customer is buying 3 parcels of land that are now zoned Industrial. On these 3 parcels are 3 run-down/burnt-out shells of Single Family Residences. The borrower intends to purchase the land, demolish these structures, and build industrial warehouse/storage facilities.

I'm inclined to think - NOT HMDA, but wanted to ask the esteemed opinion of fellow club members.

The floor is open.

The purpose of the loan is clearly business-related. I wouldn't include it on HMDA.

I just looked at my previous response and realized it was not as clear as it should have been. The funds borrowed will be used for building commercial-use property, not residential housing. Therefore, no HMDA.

Although you may have an argument on your hands at the next exam, I agree with NMB. HMDA is purpose driven. Although this property has dwellings on it, the purpose is to remove them and not make this a dwelling loan. I agree that you should not record this as a HMDA loan.

I also vote for not HMDA reportable - I echo David's reasoning.

I vote with David & Jim (but don't forget a FZD)

Thanks Dan. Luckily our Review Appraiser automatically orders Flood Hazard Verification with Life of Loan service anytime an appraisal is done on improved real estate.

Or as he puts it "We paper the walls with the darn things!"