We made a fix and flip loan in 2022 when we were not subject to HMDA. Borrowers need more money in 2023 and we are now subject to HMDA. Were making a new short term loan to cover the additional costs in 2023. As with the previous loan, the repayment of the loan will be the home being sold. The new loan is HMDA reportable. We have a new dwelling secured loan and satisfied a lien a dwelling secured loan (re-fi). However, if you make a short term construction loan and then make another loan to term it out the new loan is reported as a purchase. I think this example is just for construction loans. Would this be reported as a refinance or a purchase?

Were making a new short term loan to cover the additional costs in 2023.

Depending on the repayment source this loan would either be a refinance or not reportable.

If the short term loan will be paid by the sell of the property then you have a short term loan that would be a refinancing.

If the short term loan will be refinanced into a longer term loan when the loan matures then you have a temporary loan and those are not reportable.

Loan will be paid by the sell of the property. Refinance. Thank you.