Here is the scenario. Investment home free and clear. In individuals name. New commercial loan being made. Individuals are transferring ownership of property in their name to LLC. There is no payoff. The new loan is an equity loan. Is this a HMDA purchase since there is no payoff?

Are you saying that prior to your loan, the individuals will deed the home to the LLC? (There's really not any reason for it to be part of your loan if there's no payoff involved.) What WILL the funds be used for?

Apparently the transfer is part of the title work so that is why it is part of the loan. Regarding the proceeds purpose, I am not sure yet (need to follow up with LO), but for the sake of an example lets say proceeds purpose 1 example is to purchase additional investment property 1-4 (in this situation I think HMDA purchase is appropriate.)

In example 2 lets say proceeds purpose will be used for Working Capital. Is this still HMDA?

I agree with your assessment. Example 1--reportable. Example 2--not reportable.

Another scenario that comes into play in these situations, potentially, is that the LLC is "buying" the property from the individual with the loan funds. We have beat this topic around in another thread, but I would understand such a transaction to be a "Purchase" for HMDA. Otherwise, I agree with @Raitch. Scenario 1 is a "Purchase" and Scenario 2 is "Other," but you can't have "Other" with a business purpose, so it would be not reportable.