HMDA or not? unknown if propery was owned or not

HMDA or not?

Application declined on a commercial R/E loan (purpose of loan was for working capital)to be sucured by 3 known residential properties. It is unknown if the properties were owned free and clear or not. The app was declinded so we did not do a title search.

Would you report this as a declined refinance or not report at all since the bank has no knowledge if there were liens or not...

Thanks for you opinion in advance!

Were they planning on refinancing the properties or was it a straight workking capital loan?

They were pledging the properties as security for a working capital loan.

If the only purpose of the loan rquest is for working capital, prior liens wouldn't matter. It would not be reportable.