I’m terming a HELOC into a second mortgage…no new money, no new mortgage. The customer did get a rescission since we are taking it from a revolving to a installment loan…is it HMDA reportable?

This would be reportable as a refinance as you had to redocument the note and give new disclosures to convert to a term.

It is a refi as it is dwelling secured replacing dwelling secured to same borrower.

Is it the same for a HELOC (w/p&I pmts) being refinanced to another HELOC (w/interest ony pmts). We do not report HELOC's, but in this case would it be HMDA reportable? Thanks!

A HELOC that is refinanced into a HELOC is still optional reporting. IOW, the exemption overrules the "refinance" reporting requirement.

Great! Thanks so much David!

Thanks to you too Dan!