I think it is reportable as a refi as long as you take the home again on the new loan. The new loan and the old loan must be dwelling secured in order to be reported as a refi under HMDA. Note HMDA definition of dwelling pasted in: Dwelling means a residential structure (whether or not attached to real property) located in a state of the United States of America, the District of Columbia, or the Commonwealth of Puerto Rico. The term includes an individual condominium unit, cooperative unit, or mobile or manufactured home.
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