Dwelling secured note satisfying and replacing a dwelling secured note. There are cash out proceeds of about $6,000 going towards a secondary market loan that is a purchase of a dwelling (not the same dwelling as the refi). Would the refinance be considered a purchase HMDA-wise due to the proceeds being used to facilitate the purchase loan? I am thinking yes, but wanted to see what you all thought. Thanks!

I agree with purchase on this one.

Great! Follow up question, please bare with me. This feels like HMDA 101 but we just had an integrity review and I am a little gun shy at the moment. So the borrower is using that above loan to purchase the new property that will be their new primary residence. Do I report this loan as non-owner occupied then? At the time of the loan it would be their primary however the intent is for the acquisition for the new primary. My education in HMDA would lead me to this being a 2-non-owner occupied.

Thoughts?

Are you taking the new house as collateral, also, or just the old house? If just the old house, I would say non-owner occupied.

Just the old house.
Thank you for your help.