Answer:
No.
1003.2
(p) Refinancing means a closed-end mortgage loan or an open-end line of credit in which a new, dwelling-secured debt obligation satisfies and replaces an existing, dwelling-secured debt obligation by the same borrower.
HMDA Refi Conditions
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Question:
In order to be considered HMDA reportable as a refinance, does the loan have to payoff an existing loan to the same lender?
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