Equity from property owned by the applicant free & clear is being used to pay off a mortgage loan on an investment property owned by the borrower. The loan would be a non-HMDA reportable refinance due to the applicant's primary residence (i.e., security) being free & clear; however, I believe the transaction would be reported as home purchase in spite of the fact that the investment property is currently owned by the same applicant. Correct? Thx!!

Is the "investment" property resident real estate?

If yes, walk through the definition of refinance...a loan secured by residential estate paying off a loan to same borrower also secured by residential estate (does not have to be the same property on the old and new loans).

Your loan seems to fit this definition. It is not a purchase, nothing is being purchased, ownership is not changing.