We have some confusion as to whether this is a reportable transaction(s) or not. We currenty have financed a loan with 5 investment dwellings. The customer has applied to finance each dwelling individually, hence 5 new transactions. Individually these loans will not satisfy and replace the original loan but as a whole they do satisfy and replace the existing loan. Would each new loan be HMDA reportable? Are we overthinking this??
You are not over-thinking anything. I am not aware of anything in HMDA, Regulation C, the HMDA Guide that directly addresses this issue. I agree with your analysis – none of the loans individually satisfies and replaces the existing loan, but as a group they do meet the definition. IMO these loan are refinances, but my opinion doesn’t really count. You may want to run this by your examiner.