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We have a request for a 12-month DLOC to build a commercial shop on their land and secure it by their home. Since my bank does modifications to take their loans out to permanent financing instead of creating separate permanent financing (I know, not a great idea), would we file hmda on this transaction now as a refi instead since it would not fall under temporary financing and is being secured by their home (and paying off previous loan secured by the home)?
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