Answer:
To the best of my knowledge this is not addressed in the Q&As. In these cases, the financial institution can report them as a purchase or a refinance. However, they must be consistent in how they are reporting them. We report them as refinances.
One thing to keep in mind. Whether you treat these as a purchase or a refinance for HMDA reporting, Reg Z's right of rescission applies to all of these transactions.
First published on BankersOnline.com 2/13/06