Loan purpose must be reported on all HMDA applications. Reporting 5-Not Applicable is only permitted for purchased loans where the origination took place prior to January 1, 2018.
Official interpretation of Paragraph 4(a)(3) - 6. Purpose - purchased loans. For purchased covered loans where origination took place prior to January 1, 2018, a financial institution complies with § 1003.4(a)(3) by reporting that the requirement is not applicable.