HMDA Refinance

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    Good morning. I have a commercial note (24 month interest only with a balloon payment) secured by two 1-4 residences and vacant land which is currently being developed. The note is for the development of a subdivision. The residences it is secured by are both fully completed and I am assuming have individuals living in them. When this note comes due and refinanced into another note with the same circumstances (same security, same purpose), would this note be classified as HMDA-reportable refinance? I am thinking it would be since it has a note secured by a 1-4 that satisfies and replaces another 1-4. However, I would really like to get your opinion since the development of the subdivision would still be going on at the time of the refinance. Would it make any difference if the completed residences were unoccupied? Thanks so much for your help. Have a good day.


    A refinance must involve a new transaction that satisfies and replaces an exisiting transaction, where both the old transaction and the new transaction are secured by a dwelling. Your loan appears to fit the definition.

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