The original borrower is ABC Company, which has two outstanding loans with us. These loans are considered troubled debt. The lender has worked out a plan with the borrower. These loans will be discounted creating two new loans to be assumed in a new business name, XYZ LLC. The borrower has obtained another financial backer, is transferring the assets to this new entity, and will dissolve the old entity. The two new loans are cross-collateralized, and thus, secured by a real estate mortgage covering an assisted care facility (not transitory).
Are these new loans HMDA reportable? If so, what is the purpose, refinance or purchase?
Thank you for your time.
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.