If I term out a line of credit that was originally used to purchase mobile homes and the loan is secured by a mobile home. Would I code my HMDA as a purchase or a refinance?

Interesting question and I think it comes down to how you are "terming it out". I'll put me two cents in here since nobody else has anything to say yet, and this is just my opinion.

If you are "terming" the deal out per an option in the existing document I would say it would be a purchase, but if you are paying it off with another loan/note, I would say refinance.

Yep, Refi it is then.
This collateral was released from the original LOC and termed out with a new note & D/T.

Thanks for your help.

When you say "term out" the question is did you "satisfy and replace" the LOC. If you have loan A (dwelling secured) and then make loan B (dwelling secured) which "satisfies and replaces" Loan A it's reportable as a refinance.

Be careful of the following, it's from the section by section analysis:

MECAs. The Board did not propose any change regarding the status of modification, extension, and consolidation agreements (MECAs). MECAs are not reported because they do not meet the definition of a refinancing (satisfaction and replacement of an existing mortgage loan). A few commenters asserted, however, that MECAs should be reported because they substitute for traditional refinancings in some states, such as New York and Texas, to avoid mortgage recording fees and taxes.

The final rule does not include MECAs as reportable under HMDA. The existing definition of a refinancing establishes a bright-line test for reportable transactions. The Board believes that MECA data may be useful in certain instances, but that, under the existing loan classification scheme, the advantages of a bright- line test for determining whether a transaction should be reported—especially in reducing compliance burden— outweigh the benefits of additional data on these transactions. Therefore, the Board has not revised the definition of refinancing to include MECAs.

I don't know how to link a previous thread but here is the copy/paste:
In some cases modifications are reportable:

The Second Quarter 2011 issue of Consumer Compliance Outlook is now available on the Outlook website:

http://www.philadelphiafed.org/bank-reso...a-reporting.cfm

If the bank modifies, but does not refinance, a temporary construction loan into permanent financing, does this loan become a HMDA-reportable loan?
Yes. Comment 203.2(h)-5 explains that when permanent financing replaces a construction-only loan, the loan should be reported for HMDA. In addition, construction-permanent loans must also be reported for HMDA. In essence, the bank has replaced its temporary construction loan with permanent financing through this loan modification. Because it is no longer a temporary loan and has not been previously reported, it should be reported as a home purchase loan if it meets Regulation C's definition of home purchase.

This was not a modification, it was truly a new note and D/T.
Thanks for your help!