Is the refinance of a commercial revolving loan secured with a dwelling HMDA reportable?

If you report HELOCs (open end lines of credit), you should also report open end commercial lines of credit.

Duchess is right, but let me say it another way. The requirement to report refinancings does not trump the exemption to not report lines of credit. If your institution does not report LOC's, don't report refinancings of them either.

If you're refinancing the open-end credit to a new open-end credit I agree with Skittles and David. Open-end credits are optional reporting regardless of their purpose. However, if you are refinancing the open-end credit to a closed end credit then you do have a reportable refinancing.