203.2(K)(1)&(2) (k) Refinancing means a new obligation that satisfies and replaces an existing obligation by the same borrower, in which:
(1) For coverage purposes, the existing obligation is a home purchase loan (as determined by the lender, for example, by reference to available documents; or as stated by the applicant), and both the existing obligation and the new obligation are secured by first liens on dwellings; and
(2) For reporting purposes, both the existing obligation and the new obligation are secured by liens on dwellings.
I am a bit confused. What is the definition of covered purpose?
If I have a loan that initially was a loan for working capital, with residential real estate taken as part of the collateral.
In this example the original obligation was not a home purchase. So it would not meet the definition of …(K)(1) When that loan is renewed will it be a HMDA loan? ….(K)(2) says it is.
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Bubs-
"truth does not occur in the database" - Actual search result on a goverment website