Refinance Auto

Our customer ended up refinancing his auto loan that he had with us but he refinanced it into a mortgage loan and now has his primary residence as collateral. Should I report this as a "Other" purpose for HMDA purposes? I don't see this being any different than the customer getting a mortgage from us (cash out) and taking the cash to another bank and paying off his auto loan. Thank you.

Other is correct

Thanks rlcarey.

I haven't worked a lot with HMDA lately so I'm thinking out loud, but I assume your bank doesn't offer a cash-out refi product? (Code 32) I've always used a waterfall means to flow from one purpose to the next leaving Other as a catchall.

Code 1- If any part of the proceeds are to be used for Home Purchase, report Home Purchase.

Code 2- If any part of the proceeds are to be used for Home Improvement, and no part of the loan proceeds are to be used for Home Purchase, an Institution's separate Cash-out refinancing product, or Refinancing, report Home Improvement.

Code 31- If any part of the proceeds are to be used for Refinancing, and no part of the loan proceeds are to be used for Home Purchase or an Institution's separate Cash-out refinancing product, report Refinancing.

Code 32- If any part of the proceeds are to be used for an Institution's separate Cash-out refinancing product, and no part of the loan proceeds are to be used for Home Purchase, report Cash-out refinancing. (following the refi definition)

Code 4- Except for business/commercial loans (which must be Home Purchase, Refinancing or Home Improvement), for everything else (other than Purchases where origination occurred prior to January 1, 2018), report Other.

Code 5- Report not applicable for Purchases where origination occurred prior to January 1, 2018.