If a customer uses a credit card to pay for home improvements, and then gets a loan from us to pay off that high interest card, would that be considered home improvement for HMDA purposes? My gut says no, the purpose is to payoff cc, but the initial funds were used to make home improvements... OVERTHINKING THIS!

No, the loan purpose is to pay off the credit card.

And just another added note. If the customer had taken out a loan for home improvements and your loan paid that off, it WOULD be HMDA reportable but as a refi....not a home improvement loan. And if your loan paid off an unsecured loan at your bank for which the funds were used for home improvments, the new loan would NOT be reportable as home improvement or as refi.

Thanks swiggles!

Rocket science, my dear..........rocket science.