Answer:
Yes, this definitely is to be reported as a refinance for HMDA. Any loan, regardless of purpose, that is secured by residential real estate and refinances a loan that was also secured by residential real estate and is to the same borrower is a HMDA refinance.
A special carve out was made under CRA when the HMDA refi definition was broadened and encompassed all of these commercial purpose refinance loans secured by residential real estate.
This has been in place for quite some time.
First published on BankersOnline.com 9/19/11