We have a HMDA-reportable loan where one entity refinanced the debt of another related entity, and it went from 1 guarantor (3 owners) to the other 2 of those 3 same owners guaranteeing the loan (now just 2 owners). That being said, would you report the Loan Purpose as a purchase on the HMDA LAR...or a refinance?

You have two different borrowing entities and in order to be a refinance, the borrower must be the same. IMO you have a purchase transaction.

Thanks...

I agree that this isn't a refinance, but it would only be a purchase of the ownership of the dwelling changed as part of the transaction.