We had several loans to a business customer that were all cross-collateralized with business assets and a single-family home. One of these loans was a LOC for 500,000. The entire loan relationship was just restructured. As part of this restructuring, the majority of the balance on the LOC was converted into a new term loan. Same cross-collateralization (BA and SFH).
Normally I would say yes, this is HMDA-reportable as a refinance. However, the LOC wasn't reduced--the loan officer kept the LOC at 500,000. So I am not sure if this new term loan actually satisfies and replaces the LOC. It seems to satisfy/replace the balance on the LOC, but is that enough to trigger reporting?
Now I am confused as to how to prove one way or the other. Thoughts? Thanks!
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