Regardless of the loan's purpose if it is secured by a dwelling and is paying off another dwelling secured loan to the same borrower it meets the definition of a refinance under HMDA.
I agree with Randy...the loan being reported to the credit bureau or not has absolutely nothing to do with determining if the new loan is subject to HMDA reporting.
1003.3 Exempt institutions and excluded and partially exempted transactions.*
(10) A closed-end mortgage loan or open-end line of credit that is or will be made primarily for a business or commercial purpose, unless the closed-end mortgage loan or open-end line of credit is a home improvement loan under § 1003.2(i), a home purchase loan under § 1003.2(j), or a refinancing under § 1003.2(p);
(p) Refinancing means a closed-end mortgage loan or an open-end line of credit in which a new, dwelling-secured debt obligation satisfies and replaces an existing, dwelling-secured debt obligation by the same borrower.
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The opinions expressed are mine and they are not to be taken as legal advice.