Say you do a Home Equity Line of Credit that is a purchase money. Is this still exempt from the RESPA disclosures such as GFE, Servicing Disclsoure, HUD-1, etc...?

If the proper Reg. Z disclosures are given open-end credit plans are exempt from RESPA's disclosure requirements for the GFE, HUD settlement statement and STD.

I have a similar question but for HMDA/Reg B. If we do a purchase/HELOC (open-end) and we have not reported HELOCs for HMDA, will we need to do so for these loans? Also are we required to collect monitoring info for Reg B?

Thank you.

1. HMDA - if you do not report HELOCs you would not report purchase money HELOCs either.

2. Reg. B - yes, you would collect the GMI. You just don't report it.