Oh Dan, I still don't quite get the refi thing. I could be wrong but I thought it had to be a refinance of purchase money or home improvement money to qualify for HMDA.
We have a loan whereby we are refiancing a debt consolidation loan. This new loan is secured by the house. But it is a refi of the old consolidation loan.
Do we file on this one?
There are two refinancing definitions in the current regulation, which was changed in 2004.
202.3(k)(1) is the "coverage" definition. This definition determines if your financial institution would be covered under Reg C.
If you are covered under (k)(1), then (k)(2) gives you the "reporting" definition of a refinancing.
The loan you mention above would be a reportable refinancing.
If you haven't got a link to the GIR then you need to add the following link. The GIR will be a great help and you should become familiar with it if you are going to deal with HMDA.
http://www.ffiec.gov/hmda/guide.htm