Question - I have a question regarding HMDA and refinanced loans. The regulation states that refinancing means a new obligation that satisfies and replaces an existing obligation by the same borrower, in which, “for reporting purposes, both theexisting obligation and the new obligation are secured by liens on dwellings.” But what if the original loan, and the refinanced loan, standing alone are not HMDA reportable – is the refinance still a reportable loan?
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