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#1842090 - 08/13/13 04:57 PM Does Refi have same definition as Reg B?
NotDoneYet Offline
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NotDoneYet
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A colleague and I just noticed (hey, we do lots more than HMDA, you know?)in HMDA Getting it Right:
Refinancing means a new obligation replaces an existing obligation by the same borrower in which the existing obligation is a home purchase loan.
We have always thought the first part of that was a refi for HMDA and the second part was for Reg B, but now it seems it isn't that simple.
Your answers are appreciated.

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#1842092 - 08/13/13 05:00 PM Re: Does Refi have same definition as Reg B? NotDoneYet
manimal Offline
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manimal
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Just FYI the existing obligation doesn't have to be a home purchase loan.

From the Glossary of GIR:

Refinancing.
A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. The purpose of the loan being refinanced is not relevant to determining whether the new loan is a refinancing for HMDA purposes. Nor is the borrower’s intended use of any additional
cash borrowed relevant to determining whether the loan is a refinancing, though the borrower’s intended use of the funds could make the transaction a home improvement loan or a home purchase loan.
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#1842097 - 08/13/13 05:04 PM Re: Does Refi have same definition as Reg B? NotDoneYet
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NotDoneYet
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That's what we have always thought, but I couldn't find the part you listed.
Thanks!

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