We have an investment real estate LLC that recently acquired a residential real estate property by taking an advance on a line of credit with our bank that is secured by other assets. There was no lien on the newly acquired property.

The bank the then approved & funded a mortgage to the same borrower secured by the newly acquired res.investment real estate and paid down the Line.

We are assuming that the mortgage is HMDA reportable but would it be a Purchase or a Refinance.

At the time of the loan your customer owned the property, so it doesn't qualify as a purchase.

They did not satisfy and replace an existing loan (paid down the line), so it doesn't meet the refinance definition.

Your loan is not reportable.

The property was owned free and clear and used as collateral for the purpose of paying down a business line of credit. Not a purchase, not a refinance. Not HMDA reportable