Situation: Borrower purchased apartment building for the purpose of renovating into condos in 2006, a year in which we were not a HMDA reporting bank. In 2007 (when we were a reporting bank), loan was refinanced with additional funds for cost overruns. In 2007, do we report that as a refi or a purchase? And, if refi, do we report the entire loan amount or just the additional funds?

The original loan was the purchase transaction. Your new loan is a refinancing transaction and you would report the full loan amount.

Always report the entire amount of the loan (lines are different).

Was the 2006 loan temporary financing? If so, I would report the 2007 loan as a purchase. If not, cost overruns sound like home improvement to me, so I would get more information and most likely report as HI.

I'm not thinking too straight this...morning...I agree with hmdagal...HI instead of refinancing.

Thanks, Dan. It's always nice to hear that I'm not out in left field somewhere.