When it comes to HMDA, a refinance is reportable, but a modification generally is not. So, what’s the difference? HMDA defines a refinance in Section 1003.2(p), which states: Refinancing means a closed-end mortgage loan or an open-end line of credit in which a new, dwelling-secured debt obligation satisfies and replaces an existing, dwelling-secured debt obligation by the same borrower. The Commentary breaks this definition down even further. A modification, on the other hand, isn’t really defined. It’s just not a refinance. So, for HMDA purposes, you either have a refinance or you don’t.
Published
2021/04/27