I am torn with this loan and need some opinions...

This loan is business purpose to consolidate debt, and the collateral we have taken is several, including primary residence, investment properties (rentals) and their actual business property.

I think it would be HMDA reportable as a Refi of P/R (primary residence). ?? Any help is appreciated.

Are you paying off a loan secured by a dwelling?

yes

We are paying off 3 different loans with this new loan. But with this new loan having so many more pieces of collateral, the rentals, their primary residence, and then their actual commercial business and several lots (land only) I am choosing the P/R to report for this new loan because I've been trained if more than one property just choose one and we usually choose the one that is has the most value (appraisal) so with this new loan the business is taking out to consolidate debt I have chosen the P/R (primary residence).

But I do think it is reportable because one of the pieces of collateral is from an old loan that we are paying off this time.

Am I correct in believing this loan would be HMDA reportable?

If any of the prior debt being refinanced was dwelling secured, and the new loan is dwelling secured, and at least one borrower is the same on both loans the loan will be HMDA reportable because it meets the HMDA definition of a refinance.

I would report this as a refinance as long as you are paying off a dwelling secured loan AND it's to the same borrower.

It does not matter if the loan is secured by the primary residence, what matters is if any of the collateral is a dwelling (as defined by HMDA) of any kind.

Ok, thank you both. I did report it but I just kept doubting myself.