If we are doing a Modification that triggers RESPA/Reg Z requirements (providing new disclosures), can we report HMDA if the purpose is purchase, refinancing, or home improvement? From what I have read on this website, Modifications are not HMDA reportable but was unable to find out whether or not a Modification with new disclosures are HMDA reportable.

Thanks!

Isn't a "modification" that requires new disclosures actually a refinancing and not a modification?

(a) Refinancings. A refinancing occurs when an existing obligation that was subject to this subpart is satisfied and replaced by a new obligation undertaken by the same consumer. A refinancing is a new transaction requiring new disclosures to the consumer

Where did you get this information at?: 'A refinancing is a new transaction requiring new disclosures to the consumer'

Thanks for your response!

1026.20(a) (Reg. Z)