Is Raw Land-Real Estate reportable for HMDA?

Generally, a loan must be secured by a Dwelling to be reported for HMDA. The 2015 HMDA Rule also classifies loans secured only by vacant or unimproved land as excluded transactions.

However, a loan secured by a lien on unimproved land is deemed to be secured by a dwelling (and not might not be excluded) if you know, based on information from the applicant or borrower at the time the application is received or the credit decision is made, that the proceeds of that loan will be used within two years after closing to construct a dwelling on, or to purchase a dwelling to be placed on, the land. Comment 3(c)(2)-1.