HMDA Reporting for Refinancings of Business Loans

Compliance > Regulation C - HMDA
Q:  Is a refinancing that is a business loan reportable for HMDA purposes?

A:  Even if the loan that is being refinanced was not HMDA reportable, the refinancing will be if the refinanced and new loans are both secured by a dwelling.  For example, a loan to purchase equipment that is secured by the business owner’s home is not HMDA reportable.  However, if the business owner refinances the loan and uses the home as collateral for the second note, then the refinancing will be HMDA reportable as a refinancing.

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