We have a loan on the books that was converted from a HELOC to a term loan of 20 year. We have a Modification and Extension agreement and we also have a Renewal promissory note. Would you consider this a modification, renewal or a refi? I understand modifications are not reportable or renewals. The renewal note extends the Home Equity Line of credit Promissory note and since an additional signer was added to the loan, documentary stamps were affixed to the modification and extension agreement. Would this be a reportable transaction?

The renewal note extends the Home Equity Line of credit Promissory note

So you still have an open-end credit where you are providing periodic statements?

We are Small Bank and we are not providing statements on residential loans, for HELOC's we do but it will stop once the loan get's coverted to a 15 year mortgage loan.

for HELOC's we do but it will stop once the loan get's coverted to a 15 year mortgage loan.

Then you are converting an open-end credit to closed-end credit which would be a refinancing under Reg. Z. You are replacing the open-end obligation with a closed-end obligation and you must provide all applicable closed-end disclosures and follow all closed-end requirements.

So this should be reportable in HMDA although we did a renewal/modification?

You have a refi for HMDA but you also should have provided closed end disclosures because you refinanced the HELOC into a closed end term loan.

Had you simply modified the HELOC to a repayment period, you would have continued as with a HELOC and periodic statements, with no need to redisclose (and not HMDA reportable).