We have a commercial loan request (1 loan) to an entity that is to refinance 8 mortgages at 4 different institutions. The original loans at the 4 institutions are secured by 11 residential properties, and the new loan at our bank will be secured by these properties as well. 5 loans being paid off are in the name of our borrower and three of the loans being paid off are to a related entity. Does the fact that the three loans being paid off are to a related entity exclude this loan from being HMDA reportable?

No, a portion of the proceeds from the loan are still being used to refinance the other loans that are in your borrower's name.

Thank you!