In Reg C, the definition of a Refinance is:

(k) 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

In materials from a BOL Webinar presented by David Dickinson, a Refi is defined as:

"A new obligation that satisfies and replaces an existing obligation by the same borrower where both the existing obligation and the new obligation are secured by leins on dwellings regardless of the purpose of the existing obligation"

The Reg definition makes it sound like a Refi is only reportable when the original note is a purchase / 1st lein. David's definition does not seem to indicate that it matters much - if they are both dwelling secured, it's a reportable refi.

Can someone please clarify this for me and direct me to the cite?

Wait ... I think I just figured it out. The Reg definition has to do with coverage AND reporting, and David's has to do with reporting.

Correct?

That's correct. (k)(1) is the test to see if your institution is covered by Reg. C. If so then you refer to (k)(2) for the reporting requirements.

Perfect! I'll get through this yet ... ugh.