This is a great observation, indeedhelp, and is somewhat of a gray area where you will get two different opinions from those on these threads. I actually recorded a video on this last night (that won't be published until next week or so.) When I've taught seminars on this, I've always (tried to) word my language this way.. "...purchase or a refinance [starts to mumble and fade out...]of purchase money...."
I do that because I understand the debate, though I am (generally) in the camp that says to only collect it on a refinance of purchase money.
From the commentary:
"6. Refinancings. A refinancing occurs when an existing obligation is satisfied and replaced by a new obligation undertaken by the same borrower. A creditor that receives an application
to refinance an existing extension of credit made by that creditor for the purchase of the applicant's dwelling may request the monitoring information again but is not required to do so if it was obtained in the earlier transaction."
Here is a thread that has a great debate on this topic:
https://www.bankersonline.com/forum/ubbthreads.php/topics/2049256/Reg_B_Government_Monitoring_In
_________________________
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com