Given the following circumstances, is this reportable as a purchase, refi or not at all??

Application is for funds to pay down (not payoff) a LOC with a different lender. Funds from the LOC were used to purchase a rental property along with other business expenses. No mortgage was taken by other lender. The rental property will be used as collateral for our loan.

Thanks!

From the information you've given it doesn't meet the definition of purchase or refinance. I don't think it's reportable.

That's what I was thinking also. Thanks Duchess!