I have a home equity loan, whose purpose is debt consolidation, which would normally not be reported on HMDA. However, part of the debt consolidation is to pay off a home equity line of credit (which we don’t report), and that home equity line was used for home improvement. Is this considered a refinance, therefore, HMDA reportable? Any assistance is much appreciated. Thanks!

I'd say if you have documentation that the loan being satisfied and replaced was for home improvement and not a purchase loan, you could not report it for HMDA.

I'm at home so I don't have my GIR here but I seem to recall on a recent thread Dan confirmed that this would not be reportable. You have to be paying off the home improvement directly, not once removed, for a loan to be considered home improvement.

If the existing HELOC is being paid off (as opposed to being paid to zero) and was secured by a dwelling AND your new home equity loan is also secured by a dwelling (same borrower/not temporary financing) then you'd have a refi.

I'm with CF on this one - if you're closing the HELOC, it's a reportable refinance.

Thanks to all. I do believe it is a refi as well.

You are correct that this would not be a HI loan, but as CF and hamdgal alluded to, it could very well be a refinancing if the HELOC was closed.