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New Loan - HMDA Reportable?

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Question: 
The situation - Grandparents are purchasing a house for their grandchild. Collateral - Grandparents farmland not located where house is. Question - Is this HMDA reportable? No mortgage being taken on purchased house, only the farmland.
Answer: 

Not reportable.

Official Interpretation
Paragraph 3(c)(2)
1. Loan or line of credit secured by a lien on unimproved land. Section 1003.3(c)(2) provides that a closed-end mortgage loan or an open-end line of credit secured by a lien on unimproved land is an excluded transaction. A loan or line of credit is secured by a lien on unimproved land if the loan or line of credit is secured by vacant or unimproved property, unless the institution knows, based on information that it receives from the applicant or borrower at the time the application is received or the credit decision is made, that the proceeds of that loan or credit line will be used within two years after closing or account opening to construct a dwelling on, or to purchase a dwelling to be placed on, the land. A loan or line of credit that is not excludable under § 1003.3(c)(2) nevertheless may be excluded, for example, as temporary financing under § 1003.3(c)(3).

First published on 10/22/2023

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