My gut feeling is that this is NOT reportable, but want a 2nd opinion...

We have a commercial customer with the following set-up:
-Has a commercial revolving line of credit that is secured by equity in 10 properties
-The line is used to purchase additional properties to improve, flip, etc (never secured by the new properties being purchased)

A revolving line draw was used to purchase a property and after performing improvements the customer decided they want to keep this property for rent. They are using the equity to repay the revolving line of credit draw (not close the LOC) and will be terming it out in a stand alone note.

Unless the subject loan will zero out and close the LOC, then it isn't reportable. For HMDA, a refinance has to replace an existing dwelling secured obligation.

Thanks for the reply