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For a HMDA refinance, I have a question concerning what constitutes the “same borrower”. It is my understanding in the situation where one borrower dies, the renewal for the remaining borrower would be a refinance.
However in a divorce, when one party is buying out the other party’s interest, would you consider this a purchase or refinance?
The other situation is I am unusre of is when two borrowers are on a note and when the note is refinanced, one of the borrowers is taken off (Example: mother and son are on the original note, when the note is refinanced the note is only in the son’s name.) Would this be a refinance for HMDA and qualify as “same borrower” as long as one of the original borrowers is on the subsuequent note? Thank you very much for your help. I am confused on whether there are specific answers to these situations or whether consistency is appropriate approach.
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