Based on what you have stated, no.
The loan purpose does not meet the definitions of purchase, refinance or improvement proved by the regulation.
Home purchase loan means a loan secured by and made for the purpose of purchasing a dwelling.
Home improvement loan means:
(1) A loan secured by a lien on a dwelling that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located; and
(2) A non-dwelling secured loan that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located, and that is classified by the financial institution as a home improvement loan.
Refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. For reporting purposes, both the existing obligation and the new obligation must be secured by liens on dwellings.
Last edited by NSFW; 07/02/15 02:49 PM. Reason: Added definition
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It is better to act cautiously beforehand than to suffer afterward.
The answers I give are my opinions. Not legal advice.