Cash Out Refi Purchase 2nd Home-HMDA Location?

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Question:

We did cash out refinance on a customers primary home. The cash out was used to purchase a second home. I know this is HMDA reportable. I am thinking that a purchase trumps the refinance for HMDA. What I am not sure of is what location to use for the HMDA reporting. Should I use the home being purchased or the home being refinanced? The house being purchased is not securing the loan.

Answer:

Home purchases and Refinancings - report the property securing the loan if the property being purchased or refinanced does not secure it.

Home improvement - report the property being improved.

First published on BankersOnline.com 10/1/12