Posted By: ajthompson
GMI on HELOCs?????????? - 07/18/07 03:53 PM
Call me thick-headed, or flat out dumb; but for some reason I can't find where it says <in Reg C> that we SHALL NOT collect GMI on HELOCs. Anyone care to help a brotha out?
Posted By: arye
Re: GMI on HELOCs?????????? - 07/18/07 03:55 PM
Under HMDA (Reg. C), HELOC's are optional reporting. If you have made the decision not to report HELOCs, then you do not collect GMI under Reg. C.
You may, however, have collection requirements under Reg. B (ECOA)...see 202.13.
Posted By: ajthompson
Re: GMI on HELOCs?????????? - 07/18/07 04:00 PM
We dont report HELOCs on the LAR, but are collecting GMI anyway. Reg B gives us a way out on the PM-2nds & Refis; but looks liked we dont have an excuse for collecting it on regular cash-out HELOCs.
Just trying to find a regulatory citation.
Posted By: arye
Re: GMI on HELOCs?????????? - 07/18/07 04:42 PM
Nope...regular cash out HELOC's would not fall under the Reg. B collection requirements.
There is no cite to say "do not collect"...rather, the cite is "when to collect"