Investment covers a lot of ground - is he investing in a rental dwelling - is he investing in the stork market - is investing in a business venture - is he investing in a piece of land for resale - is he investing in his bankruptcy attorney - is he investing in a marijuana field - is he investing in a home improvement project - is he investing in a vacation home -
There are investments mentioned above that would cause the loan not to be reported as a refinance.
Also check out page D-10 of the GIR
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The opinions expressed are mine and they are not to be taken as legal advice.