We "refinanced" a HMDA Loan for a business entity. At the time of the initial loan, the business entity was named ABC Corp.; however, the Company did a restructure of the business and now this loan is being "refinanced" into XYZ Corp. My question is, would this be considered a purchase because the loan is not made to the same borrower or would we still consider it a refinance?

Was it just a name change (like a branding/DBA thing), or was it an entity change like a merger/buyout?

Ownership changed and changed the name but it was not a merger, from my understanding.

If it was the same entity and they just changed their name, I would say refinance. But hard to say from your description. It is going to be fact specific.

Ownership changed

Not a refinance - not the same borrower.

If property ownership changed prior to your loan it would not be a purchase and this loan would not be reportable.

If property ownership is changing as part of your loan transaction then it is a purchase and reportable.

Thanks Dan. The property ownership is changing as part of the loan transaction.