Borrower's taking out mortage with second home as collateral.
Using money to pay off mortgage on primary residence, car loan and get cash back.
HMDA says refinance is 'any dwelling secured loan that satisfies and replaces another dwelling secured loan' so, odd as this is, it's a refi, correct?

While I'm at it, how about refinance of an investment property that was deeded to LLC and now will be in individuals' names? Not refi because borrowers changed, correct?

Nobody else here would even begin to understand HMDA contortions so thanks for listening.

I tend to agree with you. The cash back isn't for home improvement - right?

Nope.

What about the second one? (no, you're not going crazy. I edited it in.)

There was a post recently (within the past week) on this. We had something similar and when I asked our examiner via e-mail she stated it would be a purchase - even though the deed had been changed a few months before. The majority on BOL stated it wasn't HMDA reportable. Obviously I reported ours how she stated and kept a hard copy of the e-mail with our documentation.

In your case is the deed changing with the new note? If so, I'd consider that a purchase.

If the house was "deeded" at closing then I would report as a purchase...but I'm not a "guru".

Should have searched first...I apologize.

Hello Truffle Royale

I recommend reviewing this HMDA Getting It Right Primer. I review this pdf for the quirky loans that show up on our LAR.

http://www.bankersonline.com/tools/compliance/hmdaguide_pdf.html

In my opinion this loan request would be HMDA reportable. The borrower is just moving the mortgage from the primary residence to the secondary residence and paying off additional debt. The loan purpose would be a refinance unless the cash-back would be used for home improvement. Then the loan purpose would be home improvement.

Did not know that document even existed!
I'd be so much better read if I just didn't have to work at other stuff all day long.

Thanks for posting the link. I'll be printing that puppy out and hanging it on my wall at work.