I am looking for direction regarding whether or not a loan should be reported to HMDA.

My FI is refinancing a property that has 1 existing lien on it.
We are doing a 1st and a 2nd to pay off the 1 lien. No cash-out for home improvements or to purchase another dwelling.

Would both loans be reported to HMDA as a Refinance, as both loans, together, are satisfying and replacing an existing dwelling?

OR would neither be reported?

Thoughts?


Thank you -

Both loans would be reportable as refinances IMO, as together, they satisfy and replace a dwelling-secured loan.

Report both as refis assuming same borrower and both new and old dwelling secured.

Thank you so much Raitchjay and Kaybee.