Okay, we have a refinance with multiple purposes for the loan proceeds. One purpose of the refinance is to buy out a couple partner's interests in a commercial building (not a mixed use building). The rest of the refinance's proceeds will be used to improve a dwelling by adding a roof (entirely separate from the commercial building being purchased). To sum up, 96% of the loan proceeds are being used to buy out some partners who share ownership of a commercial building, 4% of the loan proceeds are being used to improve a dwelling. Is this HMDA reportable?

If this is a refinance of a dwelling-secured loan (you don't mention that), it's reportable as home improvement. The definition of home improvement says the purpose can be "in whole or in part" to improve a dwelling. If you aren't refinancing a dwelling-secured loan, it would be reportable only if your bank classifies it as a home improvement loan.

Is a dwelling securing the loan?

Do you classify non-dwelling secured loans for home improvement purposes as home improvement loans?

If you answer yest to either one of these questions then it's reportable as a home improvement loan.

We found out that it was a dwelling secured loan replacing another dwelling secured loan, so HMDA reportable for sure. Thank you for the guidance.

Since it's dwelling secured, the purpose would be home improvement since your original post indicated that some of the proceeds are being used to improve a dwelling.