We have a new loan with an individual and business listed as co-borrowers. They are using the proceeds to refinance existing debt on multiple properties. A few properties are in the individual's name only and the others are in the business name only. Being as the new loan is in the business and individual name would this not be HMDA reportable as the borrowers on the loans being paid off techinically do not match the new loan?

See this thread for similar question.