We have a borrower whose company owns the home they live in. They would like to "refinance" the home into their personal names. For TRID and HMDA purposes, am I correct in thinking this is a purchase transaction?

I assume when you say "refinance in their personal name" you mean the company is transferring title to the individuals for assuming the debt against the property. I would classify that as a purchase.

Agreed. Thank you so much.

FWIW, I agree. In my head it makes sense to think of it as the individual is buying the house from the company. Therefore it's a purchase.