if the initial loan is not to purchase, refinance or improve a residence, the initial loan is not HMDA reportable. Refer to the definition of application for HMDA purposes:
"Application. (1) In general. Application means an oral or written request for a home purchase loan, a home improvement loan, or a refinancing that is made in accordance with procedures used by a financial institution for the type of credit requested."
More detail is provided in the HMDA Getting It Right Guide and FAQs.
A commercial loan secured by residential real estate is reportable when it is refinanced. Refer to the definition of refinance.
"Refinancing means a new obligation that satisfies and replaces an existing obligation by the same borrower, in which:
(1) For coverage purposes, the existing obligation is a home purchase loan (as determined by the lender, for example, by reference to available documents; or as stated by the applicant), and both the existing obligation and the new obligation are secured by first liens on dwellings; and
(2) For reporting purposes, both the existing obligation and the new obligation are secured by liens on dwellings."