A customer obtained a lot loan with us. It is now being refinanced. During the term of the loan, the customer put a mobile home on the property and immobilized it. Technically, by immobilizing it it became part of the security interest we had in the lot.

So, is this a refinancing for HMDA or NO because when the original lot loan was originated, no dwelling was involved?

Q. Is the current loan secured by a dwelling?

Technically, by immobilizing it it became part of the security interest we had in the lot.

A. Yes.

Q. Will the new loan be secured by a dwelling?

Technically, by immobilizing it it became part of the security interest we had in the lot.

A. Yes

Q. Are the borrowers the same for both loans?

A customer obtained a lot loan with us. It is now being refinanced.

A. Yes (assumption)


(p) Refinancing means a closed-end mortgage loan or an open-end line of credit in which a new, dwelling-secured debt obligation satisfies and replaces an existing, dwelling-secured debt obligation by the same borrower.