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Must All Refinances Be Secured w/ A Dwelling?

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Question: 
Customer is refinancing a commercial real estate mortgage secured by commercial real estate. Is this HMDA or must ALL refinances (whether consumer or commercial) be secured with a dwelling?
Answer: 

HMDA only deals with residential real estate (or unsecured home improvement under certain circumstances). If the property referred to as commercial real estate is rental residential real estate and the loan otherwise meets HMDA refinance rules (same borrower on original and refinanced loan, both loans secured by residential real estate, original loan is totally replaced by new loan), it will be a refinance for HMDA purposes.

First published on 04/14/2014

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