Bank orginated two separate loans one was a HELOC (secured by a second mortgage on the property) and the second was a loan secured by a mobile home, 4 wheeler, and two trucks. Now bank is refinancing these two loans into one loan. We opt not to report HELOCs for HMDA, but since the mobile home is involved in one of the existing obligations and the new obligation, isn't this HMDA reportable? Any feedback is appreciated.

Is the new loan a HELOC?

If it is, and your bank does not report HELOC's for HMDA, then it is not reportable.

If it is not a HELOC, yes, it's a reportable refinance, if it's secured by a dwelling.

I agree with #12.


And even if the MH wasn't involved in this situation, if you refinance a HELOC into a dwelling secured closed-end loan then it is a reportable refinancing. The fact it was a HELOC is no longer a factor. The new closed-end loan meets the definition of a refinancing.