The definition of a home improvement loan is (a) any dwelling-secured loan to be used, at least in part, for repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which the dwelling is located, and (b) any non-dwelling-secured loan (i) that is to be used, at least in part, for one or more of those purposes and (ii) that is classified as a home improvement loan by the institution. Based on my interpretation of the definition, loans to reimburse a borrower for expenses previously incurred in connection with home improvements, would not be covered. Is that correct? I welcome your perspectives.

Loan funds are not being used for home improvement, therefore, unless the funds are used for another reportable purpose such as purchase of a residential property, the loan is not HMDA reportable.