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If the bank has a loan to refinance an existing dwelling secured loan by the same borrower, and it requests additional money to purchase a computer, is that considered a cash-out refinancing for HMDA 2018 purposes?

My question is regarding the Home Mortgage Disclosure Act (HMDA) loan purpose: refinance vs cash-out refinance. If the bank has a loan to refinance an existing dwelling secured loan by the same borrower, and it requests additional money to purchase a computer, is that considered a cash-out refinancing for HMDA 2018 purposes? When the bank is setting the terms of the loan, it does not treat a refinancing any different from a cash-out refinancing.

If the bank does not treat the cash-out refinance as a different product than its refinance, the bank would report these as refinances. See the commentary at §1003.4(a)(3)-2-iii which says:Assume a financial institution does not distinguish between a cash-out refinancing and a refinancing under its own guidelines and sets the terms of all refinancing’s without regard to the amount of cash received by the borrower at closing or account opening, and does not offer loan products under investor guidelines. In this example, the financial institution reports all covered loans and applications for covered loans that are defined by § 1003.2(p) as refinancing’s for purposes of § 1003.4(a)(3). (July 2017)

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