Customer pays off an existing line of credit (for business purposes) that was secured by his personal residence. The new line of credit (also for business purposes) will also be secured by his personal residence.

Is this a HMDA reportable refinance? I say no, but I'm looking for some help.

I agree with you, assuming we're talking about open-end LOCs. The FAQs state that a dwelling-secured line of credit that satisfies and replaces another dwelling-secured obligation is NOT required to be reported.....

Doh...I just read that in the FAQs. Thanks for replying raitchjay. I pulled the trigger a little prematurely with posting my question. Should have referenced the FAQs first.