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Is This HELOC Renewal Considered a Refinance?

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We have a home equity line of credit at renewal. We do not assign a new loan number, but we do prepare a new promissory note. The intended purpose of the renewal is for school tuition. Is this renewal considered a refinance and HMDA reportable?

From your description it appears your new note satisfies and replaces the existing note, therefore you have a refinancing. HELOCs are optional reporting, so if you report HELOCs this would be reported as a refinancing.

First published on 10/27/08

First published on 10/27/2008

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