We think we're right, have read previous posts, the Q&A, staff interpretations, Getting it Right, consulted our Magic 8 Ball, and Miss Cleo. With that said, we'd still like a 48th opinion.
We have a loan that is the permanent financing of a construction loan on commercial RE. The loan also has a second mortgage on non-owner occupied residential RE owned by the same borrower to provide extra equity.
We're comfortable that the construction loan with the purpose to construct commercial property was not HMDA reportable. However, we're convinced that the separate loan to provide permanent financing is HMDA reportable since it is a refinance of a dwelling secured loan. This seems counter-intuitive and makes no sense, but we can't find any other thing to tell us that we're wrong. Are we right?
TIA
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