Collect GMI on a HELOC?
Randy Carey, BOL Guru Guru Bio
Question: Is there ever a circumstance in which government monitoring information would be collected for a home equity line of credit?
Answer: If you are aware that the HELOC is being used to purchase or refinance the purchase of a primary residence, then GMI would be required:
Sec. 202.13 Information for monitoring purposes.
(a) Information to be requested—(1) A creditor that receives an application for credit primarily to purchase (or to refinance a home purchase loan) a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, ....
OSC 202.13(a) - Comment 5 - An application for an open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling.
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