We have a loan to a consumer (for a consumer purpose) secured by a dwelling that will be paying off a short term (non-reportable unsecured) loan that was used for home improvement and to pay off credit cards. I believe this loan is not HMDA reportable because the original loan being paid off was not secured by a dwelling - am I correct? I should know this answer but something about it is making me feel unsure
rrush is correct. This is a home equity loan. As you say, it also doesn't meet the definition of "refinance" because the old loan was not dwelling secured.