Under Regulation C / HMDA, why are there two definitions of "refinancing," one for "coverage" and one for "reporting"?

Compliance > Regulation C - HMDA > FFIEC FAQs
Q:  Why are there two definitions of "refinancing," one for "coverage" and one for "reporting"?  [Regulation C / HMDA]
 
A:   A lender uses the reporting definition, 203.2(k)(2), to determine whether to report a particular application, origination, or purchase as a "refinancing" in the loan purpose field; a lender uses the coverage definition, 203.2(k)(1), to determine whether the institution has sufficient home purchase loan activity, including refinancings of home purchase loans, for the institution to be covered by HMDA.. See 203.2(e)(1)(iii), 203.2(e)(2)(i) and (iii). The coverage definition is not relevant to determining whether to report a particular transaction as a refinancing.
 

This can be found in FFIEC’s FAQs on HMDA-related questions, which can be found at:  http://www.ffiec.gov/hmda/faq.htm

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