Well, if I have previously owned a piece of bare ground and decide to build a house, that is considered a purchase transaction under HMDA is it not?
I think a harder question to answer is if there is also a current loan that is being refinanced at the same time they are building a new house is whether that previous loan would be considered an existing, dwelling-secured debt obligation, if the dwelling is no longer there?
It sort of makes your head swim.
This might be worth a call to your EIC to run the various scenarios by them for their opinion.
(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.
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