What an interesting situation. I’ve literally read this a few times just to get a decent grasp on it.
This is strictly information that is MY Opinion. I do know HMDA quite well but this is a situation where I don’t even think you’d find it in the GIR.
1st loan – HMDA reportable. – PURCHASE – Although Bridge loans are exempt, they’re exempt because they’re temp financing. This one is a long term loan.
2nd loan – You said you paid off the original loan and added new money. Therefore, I’m assuming (bad idea right?) that you have a new note and new D/T. – HMDA Reportable REFI. I know this is only a 12 month loan and usually those are temp and exempt but the repayment method you show is only a short term loan. (I think, Jack you may need to assist here.)
So, that’s my opinion. I’d love to hear what anyone else has to say. 😐