CRA or HMDA - Two questions:

Build a barn and loan is secured by mortgage on farm??

Refinance loan with a mortgage on farm and build a barn??

I always get confused with farm loans vs HMDA. Is a barn home improvement? And second case if you refinance the mortgage on the farm and build a barn with the new loan is it a refinance and HMDA or farm and CRA?

Let me first say that I don't know much about CRA. As far as HMDA goes, I would not consider building a barn on agricultural property to be home improvement, even if there is also a dwelling on the property. Others may disagree.

Therefore, I would not report your first situation (building the barn). I would report the 2nd as a refi for HMDA purposes. We don't get an 'out' with refinancing agricultural property like we do when purchasing it.