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We recently had an FDIC Data Specialist HMDA pre-exam review. One of the specialists indicated that applications primarily for ag/farm loans are excluded from HMDA coverage. I know in the Guide to Getting it Right the rule for purchase is very clear. However, I can’t find anything as definitive for refinance or home improvement. Do we look to the purpose first and if it is primarily ag/farm (or even commercial non residential) then stop? The examiner referred me to an FDIC Q&A that discussed two properties securing an application for a refinance where the primary property was commercial non real estate. He told me I could just insert ag/farm in place of commercial buidling and follow the same logic. Obviously, we will follow what the examiner gave us, but I would like to see this in a guide, regulation, or commentary or hear if others are getting the same error on their HMDA exams.
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