We have an application to purchase an investment property that is a little different. Our applicant has given cash to the seller (down payment) and has agreed to pay off the seller’s existing loan with the proceeds of his new loan. Unfortunately, this was a bankruptcy situation and the seller jumped the gun and has already executed a warranty deed, even though she has not been fully paid, or in this case, released from the debt on her home. Is this considered a home purchase loan for HMDA purposes? Or, is this like the post yesterday -- since title has technically already transferred, it's not subject to HMDA at all?