Answer:
The HELOC is not being satisfied and replaced by by the new obligation therefore it (the new obligation) does not meet the definition of a refinancing.
First published on BankersOnline.com 4/30/12
Loan Reportable Under Refinance Definition?
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Question:
Purpose of new loan is to pay down a portion of an existing loan secured by a dwelling and new loan is secured by a dwelling. Is this a HMDA reportable loan under the refinance definition? Purpose of new loan is to term out the outstanding balance on a LOC that was secured by a dwelling and replacing it with a new loan secured by a dwelling, however the LOC is not closed it will remain open for future advances. Is this a HMDA loan reportable loan under the refinance definition?
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