Personal Loan to pay a builder

Hello, Lender is making a personal (unsecured) loan to a customer for the purpose of paying down a mortgage and to make a payment to the builder that constructed their home.

My thought is that this is not HMDA reportable even with the possible Home Improvement purpose. My reasoning is that it is like paying the VISA bill for purchases that included home improvement type things. As convoluted as it seems.

What are your thoughts out there?

It sounds like they're paying for the construction of the home, which would be a purchase. Loans for purchase or refi have to be secured by a dwelling to be reportable, so I don't think this is a reportable loan.

THank you HMDAgal, I was wrong but right! Hehehe.

Are they actually paying for the construction - or is the home constructed and the customer is just making a payment to the builder. I don't necessarily see this as automatically reportable.

The customer is paying the builder for their already constructed home.

Not reportable.

Thank you for all of your input!