Its not 4a as it does not meet the deffination of 4a in the call code instructions. (real estate secured)
Here are a couple of items from HMDA geting it right Guide
Refinancing._Refinancing means a loan transaction in which the existing obligation, involving either a home purchase or a home improvement loan, is satisfied and replaced by a new obligation.
Data to be excluded.
Do not report loans or applications for loans of the following types:
1. Loans that, although secured by real estate, are made for
purposes other than home purchase, home improvement, or refinancing (for example, do not report a loan secured
by residential real property for purposes of financing college tuition, a vacation, or goods for business inventory).
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