Since the ownership of the property is being transferred, I would report this as a purchase. The fact that the owners of the property are also going to own the LLC is really just smoke and mirrors - technically they do indirectly own it, but from a legal perspective the LLC is a new and separate entity, and that is how we look at it for HMDA.
The bottom line is that the ownership has changed, so this should be reported as a purchase for HMDA even if the customer doesn't really view it that way for what they are doing.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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