HMDA Coverage Question

I have a bit of an oddball scenario and I want to make sure I am thinking correctly.

Chain of Events:

-Commercial borrower's application purpose says "refinance rental property" App date 8/10

- Act of Donation was executed 10/20 granting borrower the property with a clause that states Donee accepts and assumes the debt associated with this property as consideration for the "donation." I do not see any paperwork where the bank holding the mortgage that is being "assumed" has agreed to this assumption.

-Loan Closed 10/21- Funds were disbursed to pay off loan donor's mortgage loan.

Not HMDA reportable right? Not a refinance because the debt was not in the borrower's name, even though they "assumed the debt". And not a purchase since it was donated outside of loan closing the day before.

I have been staring at this transaction a little while and need a second opinion!

Did your title policy insure this transaction as a purchase or a refinance? I doubt that the property was actually transferred the day before loan closing regardless of whatever an "Act of Donation" might be - but maybe?

I do not have the final title policy, but the title commitment does indicate that it was a purchase transaction, as an executed deed was one of the conditions.