What is your collateral? If the lot is collateral on the loan, this transaction should have the purpose of purchase on the Loan Estimate and Closing Disclosure. If only the secondary residence is collateral, it should be reported as a refinance (if the loans being paid off are also secured by the secondary residence). The amount of money going towards purchase or refinance is not a factor in how you report the purpose of the loan.
I can't help you with ComplianceOne though, sorry!
Last edited by #12; 04/22/16 02:46 PM.
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