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October 29
Documenting an Applicant's Intent to be a Joint Applicant;
David Dickinson

November 4
Issues with Deceased Customers;
Mary Beth Guard and John Burnett

November 5
Vault Burglaries, Floods, Fires & Other Disasters;
Dave McGuinn

November 6
MLO v LO - Who Has to Do What?;
Jack Holzknecht and Mary Beth Guard

November 13
Domestic Violence & Workplace Violence: There Is A Link;
Shelly Collins and Dana Turner

November 18
Understanding USPAP and Regulatory Guidelines for Appraisal and Evaluation Compliance Reviews;
Eric Collinsworth



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#777536 - 07/18/07 11:53 AM GMI on HELOCs??????????
curly___ Offline
100 Club

Registered: 08/24/04
Posts: 247
Loc: SE, OK
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?

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HMDA
#777541 - 07/18/07 11:55 AM Re: GMI on HELOCs?????????? [Re: curly___]
arye Offline
Gold Star

Registered: 10/07/04
Posts: 464
Loc: Ohio
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.

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#777543 - 07/18/07 12:00 PM Re: GMI on HELOCs?????????? [Re: arye]
curly___ Offline
100 Club

Registered: 08/24/04
Posts: 247
Loc: SE, OK
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.

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#777596 - 07/18/07 12:42 PM Re: GMI on HELOCs?????????? [Re: curly___]
arye Offline
Gold Star

Registered: 10/07/04
Posts: 464
Loc: Ohio
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"

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