Does this still apply to 2018 HMDA as far as purpose goes?
If so, then would you interpret this statement "refinancing plus cash out for new investment opportunities" as real estate specific? Thus, reporting the loan as a purchase? Or is that statement too general?
This is from the 2018 rules: A financial institution may rely on the oral or written statement of an applicant regarding the proposed use (purpose) of covered loan proceeds. [Commentary to §1003.4(a)(3) #1]