Answer:
A financial institution is covered by HMDA if:
- It has an office in a MSA;
- It has more than $32 million in assets;
- Its deposits are insured by the FDIC; and
- It originates at least one home purchase loan or REFINANCE loan secured by a first lien on a dwelling.
For coverage purposes (is the institution covered by HMDA), the refinanced loan must be a first lien. For reporting purposes (does the loan go on the LAR) the lien status doesn't matter.
What gets reported as a refinance in the future is fairly broad. A loan is a refinance if:
- The institution makes a loan secured by a dwelling:
- Any portion of that loan is used to pay any existing debt, at any institution, regardless of the purpose of that debt; and
- The existing debt is also secured by dwelling.