Brain compromised today....

If we choose not to report HELOCs, do we have to collect GMI on them?

I believe on a HELOC you would only collect GMI if it is apparent that the purpose is for the purchase or refinance of the principal dwelling from a Reg B standpoint. I'm not much help on HMDA...

Agreed.

If you chose not to report, you would follow the commentary for ECOA 1002.13(a)5
An application for an open-end home equity line of credit is not subject to this section [information for monitoring purposes] 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.

Some comments from HMDA GIR

Home equity lines of credit (HELOCs)for home purchase or improvement may be reported at the institution’s option.

d. If you opt to report homeequity lines of credit, report only the portion of the line intended for home improvement or home purchase.

An institution that opts to report home-equity lines reports the disposition of all applications, not just originations.

You have two different Regualtions with requirements, Reg B and C.

Reg B 202.13 (a) and the Offical Staff Interpation state that you would collect GMI on a primary dwelling if it is Home Purcahse or Refinance, even if you do not report it due to Reg C.

Sec. 202.13 Information for monitoring purposes
(a)Information to be requested--(1) A creditor that receives an application for credit primarily for the purchase or refinancing of 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, shall request as part of the application the following information regarding the applicant(s)

** OSI 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.