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I have a loan that was made for the purpose of reimbursing the borrowers for their expense in purchasing a piece of rental property. They just purchased it in August and want to borrow the money to reimburse their savings account. Would this be HMDA reportable as a purchase?
A home purchase loan must be for the purpose of purchasing a dwelling and the loan must be secured by a dwelling. Your question didn’t mentioned whether the loan was secured or not. Even if it is secured, the loan is not for the purpose of purchasing a dwelling. There apparently is no transfer of title at the time your loan occurs.
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