Cash out to purchase partial interest - HMDA?

I know we've talked about this before but I didn't have any luck with my search.

3 sisters inherit house free and clear. Sisters 1 and 2 are buying out sister 3, take a 1st mtg on house to do so. Is this a HMDA purchase or just a non-reportable cash-out?

We would treat this the same as a spouse buying out the other spouse in a divorce situation. Since there is no existing lien on the property we would treat it as a purchase. If there was an existing lien that was being refinanced, we would report it as a refinancing.

Thanks Dan, I was having a very brain-dead day.