Also from the GIR:
Refinancing. A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. The purpose of the loan being refinanced is not relevant to determining whether the new loan is a refinancing for HMDA purposes. Nor is the borrower’s intended use of any additional cash borrowed relevant to determining whether the loan is a refinancing, though the borrower’s intended use of the funds could make the transaction a home improvement loan or a home purchase loan. See the definitions of “home purchase loan” and “home improvement loan.” Also see the rule on multipurpose loans on page 12.
And from the FAQs
Refinancing --- line of credit. If a dwelling-secured line of credit satisfies and replaces another dwelling-secured obligation, is the line required to be reported as a "refinancing"?
Answer: No. A dwelling-secured line of credit that satisfies and replaces another dwelling-secured obligation is not required to be reported as a "refinancing," regardless of whether the line is for consumer or business purposes.
From your cite:
Home equity lines of credit (HELOCs) for home purchase or improvement may be reported at the institution’s option.
This says HELOCs that are for a home purchase or home improvement MAY be reported at the FI's option. It does not excuse the reporting of a HELOC that meets the definition of a refinancing, however the Q&A does.
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The opinions expressed are mine and they are not to be taken as legal advice.