HMDA Refi HI loan question

We are refinancing a loan that was used for HI by the borrower. Is this loan HMDA reportable?

If you are satisfying and replacing a lien with another dwelling-secured lien for the same borrower, then yes, it is HMDA reportable. It does not really matter what the purpose of the previous loan was. It only matters what the purpose of proceeds of the current loan is. Are any of the proceeds going to Home Improvement again? If so, this would not be classified as a refinance, rather it would be a HI loan.

I should clarify the above post. The loan we refinanced is unsecured. There were no new money advanced, so I'm leaning to the "not reportable" side of the argument.

You are leaning in the right direction.

Now that I know the details, I am leaning that way too...

leaning way to the right in my chair...falling over...can't get up...

If there was "new money" advanced to this HI unsecured refinance, and the new money was used for something other than HI, would this be reportable as a refinance? Both the original and refinanced loan are still unsecured. If the new money was used for HI and the 2 loans are still unsecured, would it be reported as a HI loan or not reported at all?

An unsecured refinancing of an unsecured HI loan is not reportable unless a portion of any new money will be used for HI purposes and the new loan is classified as a HI loan. It would then be reported as a HI loan.

If there was "new money" advanced to this HI unsecured refinance, and the new money was used for something other than HI, would this be reportable as a refinance?

No. Both loans have to be secured by a lien on a dwelling to be reportable as a refinance.

If the new money was used for HI and the 2 loans are still unsecured, would it be reported as a HI loan or not reported at all?

If the new loan is classified as a home improvement loan, it would be reportable as HI. If you do not classify your HI loans, then it would not be reportable at all.