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Refinance by same Borrower?

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  • #5283
    TheBank
    Participant

    To meet the HMDA definition, a refinance must be by the same borrower. We frequently have loans were an entity refinance into the principal owner’s name or an individual refinances into the entity name. I am considering partnerships, LLCs, and corporations as entities, but not sole proprietorships. Does this sound correct?

    #5297
    rcooper
    Member

    What you have described would be a change in borrowers.

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