I find myself losing confidence in the final hour. A business revolving line of credit is secured by an apartment, a second mtg, etc. - was never reported as HMDA before. Now in 2004 it is renewed. Because it is a dwelling secured loan being replaced by a dwelling secured loan it should be reported, but because it is a revolving line of credit should it not be. If the line of credit was being put on payments with the same collateral would it be reported?

There are a couple of issues here. Does your bank report HELOCs? If you have chosen not to report these, then you wouldn't report business lines either.

Also, a renewal by definition is not the same as a refinance. If you closed out the initial line of credit and paid it off with a new line of credit - that would be a refinance. If your customer signed documentation to 'renew' the loan and everything stayed the same (i.e. lona number, original date, etc.) that is a renewal. Renewals are not HMDA reportable.

sorry for being unclear.

It was a 12 month revolving line of credit. We will renew it with a new promissory note, loan number, and pledge of the dwelling.

As long as it remains a LOC it would still be exempt, unless you report LOCs. If the new promissory note is actually replacing and satisfying the existing note, and you are putting it on a closed end payout agreement , then you now have a refinancing and it would be reportable.

thank you