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The refinance would be covered under HMDA.

The initial 6-month loan likely would have been excluded under the temporary financing exemption; however, the refinance could not. The definition of temporary financing is a loan or line of credit designed to be replaced by separate permanent financing extended by any financial institution to the same borrower at a later time. The 6-month loan fits this definition.

The new new loan fits the definition of a refinance – closed-end mortgage loan or 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.