"A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower" Pg 29 of GIR.
Temporary financing exclusion does not apply to refinancings, only purchase/improvement.
I believe you are OK on the HPML exclusion (though I would watch that policy for UDAP or UDAAP violations, depending on your regulator). I'm not 100% on that part, though.
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