If a customer takes out a home equity installment loan in order to payoff but NOT close their HELOC, is that installment loan HMDA reportable? I want to say no because technically there was no mortgage satisfied, but I'm not absolutely positive.
Now, the HELOC is in 1st lein position and the HEIL is in 2nd.

It is neither replacing or satisfying the current loan:

Refinancing. A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower.