7 year note on the parent's primary dwelling (previously free and clear) to finance the construction of their kid's home. The plan is after the construction is complete the will refinance using the same property (parent's primary) as collateral. Is this HMDA?

Bump

Based on the information provided the parents' loan meets the definition of a home purchase and being a 7 year note it would be difficult to justify it as a temporary loan.

IMO, reportable.

Thank you!