We are doing a refi of business propery which is HMDA reportable. The property is currently titled in the individuals name but with this refi, the property will be titled in the LLC's name. Would you consider this a refi or purchase. I could see it going either way, just looking for some guidance.

I would code it as a purchase since your borrower is changing, even if the LLC members are the same individuals that currently own the property. I've done this in the past and used the following citation from page 8 of GIR as my justification (emphasis mine):

Is your borrower changing? You don't mention that.

Yes, the borrower is changing to the LLC, but I just found out we are not issuing a new deed of trust.

In that case, I'm not sure you even have a reportable transaction.

- Not purchasing a property since ownership is the same
- Not for home improvement, based on data you provided
- Not a refi since borrower is not the same.

One of those that falls between the cracks.

Ok, good. That was what I was thinking but needed some reassurance! Thanks!