Okay ...I know I am opening myself up for scrutiny here, but please let me ask this question without embarrassment:

Old loan made for the purpose of purchasing a vehicle, the home is taken as collateral also. We refinance the loan before the term is up and keep the vehicle and home as collateral ...IS THIS now HMDA reportable as a refinance?

I say yes ...but am getting push-back from my lenders.

I attended the NRCC in Chicago last week and attended all sessions that discussed the subject above.

This is definitely a refi under the new HMDA definition.

From page 28 of the 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.

Bless you!!!!