CY2016 (look back): We did an Amended, Restated and Increase Renewal Promissory Note, the original purpose of the loan was to purchase an apartment building. The new money would it be reported in HMDA for the amount of the new money or do I report the full loan amount? would it still be "purchase" for purpose?

Is this a refinance or a modification of the original loan?

The original loan was extended and new money funded.

Sounds like an unreportable modification to me.

In previous situations where we had a loan and we provide new money by increasing the loan, I was told by an FDIC examiner that by providing new money it makes it reportable. If I remember correctly, I had to report the loan for the entire amount and not just the new money.

If the existing obligation was modified the transaction is not reportable.

If the existing obligation is satisfied and replaced with a new obligation then it is a refinancing that would be reportable.


What you have to determine is does the Amended, Restated and Increase Renewal Promissory Note modify the existing obligation or does it replace the existing obligation?

I agree. Modifications/extensions/renewals (whatever you want to call them) are NOT reported. You can find the proof here:
Commentary to §1003.2(d) #2, Commentary to §1003.2(o) #2 and Commentary to §1003.2(p) #1(iii).