HMDA purpose: The 1st mortgage will be used to purchase the property as a primary residence.
The additional 2nd mortgage HELOC is being requested for personal expenses.
In this scenario – is it acceptable to record the HELOC as a “other” for HMDA purposes? No other purposes applies (it is not refinancing and is not HI). Or would it also be recorded as a “purchase” because it is simultaneous with 1st mortgage?
You’re on the right track. If the HELOC 2nd lien did not involve a refinance or funds for HI or to purchase a dwelling, the HMDA loan purpose would be 4-Other. It originating at the same time as the purchase mortgage transaction means nothing unless proceeds were disbursed to help with that purchase.