Loan made to construct barn with living quarters (primary residence until construction of home) in 1st lien position...Private contract for land purchase with existing structure (mobile home) in 2nd...now paying off construction loan and replacing it with a home equity loan...obviously the construction loan was never reported for HMDA purposes but the purchase of the land/existing structure was not reported either as it was done through a private party....So, my question is this...Do I report this loan as a purchase or a refinance?
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