*Borrowers are taking a loan on their second home, no current mortgage to payoff. *They're using the funds to payoff the mortgage on their third home. I'm thinking it's not HMDA but my brain is in rum withdrawal from vacation...either that or I sunburned it! Thanks for the help.
Welcome back Truff! If they are satisfying and replacing a loan secured by a dwelling with another loan secured by a dwelling, it's a refi. The dwellings don't have to be the same!