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#1023456 - 08/19/08 09:11 PM Reporting HELOCs on HMDA LAR
Audit Girl Offline
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Audit Girl
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Oklahoma
Question: I understand that a institution may chose to report HMDA Loans. Can they decide to only report some HELOCS? For example the HELOCS that it is evident that the line will be used to purchase their primary residence?

Thanks for the help or the direction to the information.

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#1023515 - 08/19/08 10:20 PM Re: Reporting HELOCs on HMDA LAR Audit Girl
rlcarey Online
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rlcarey
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Galveston, TX
GIR guidance - Home equity lines of credit (HELOCs) for home purchase or improvement may be reported at the institution’s option. Report only the amount that is intended for home purchase or home improvement purposes. An institution that reports home equity credit line originations must also report any applications that do not result in an origination.

IMHO - It is an all or nothing proposition.
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#1023582 - 08/20/08 12:45 AM Re: Reporting HELOCs on HMDA LAR rlcarey
David Dickinson Offline
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Central City, NE
FWIW, I agree with Randy. You report all LOC's for purchase, improvement or refinance. You can't pick and choose.
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#1024005 - 08/20/08 03:58 PM Re: Reporting HELOCs on HMDA LAR David Dickinson
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Randy and David, thank you for your help.

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#1029259 - 08/27/08 06:32 PM Re: Reporting HELOCs on HMDA LAR David Dickinson
RegsRfun Offline
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Floating in compliance land...
Originally Posted By: David Dickinson
FWIW, I agree with Randy. You report all LOC's for purchase, improvement or refinance. You can't pick and choose.


HELOC's are only reportable for Home purchase & home improvement. Home refinance are not reportable. A quote from the HMDA Getting it Right Guide:

"Home equity lines of credit (HELOCs) for home purchase or improvement may be reported at the institution’s option. Report only the amount that is intended for home purchase or home improvement purposes. An institution that reports home equity credit line originations must also report any applications that do not result in an origination."

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#1029286 - 08/27/08 06:53 PM Re: Reporting HELOCs on HMDA LAR RegsRfun
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I disagree with this Regs. The definition of a refi would cover HELOC if you chose to report them for purchase and HI.
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#1029288 - 08/27/08 06:54 PM Re: Reporting HELOCs on HMDA LAR RegsRfun
Dan Persfull Offline
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Bloomington, IN
Also from the GIR:

Refinancing. A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. The purpose of the loan being refinanced is not relevant to determining whether the new loan is a refinancing for HMDA purposes. Nor is the borrower’s intended use of any additional cash borrowed relevant to determining whether the loan is a refinancing, though the borrower’s intended use of the funds could make the transaction a home improvement loan or a home purchase loan. See the definitions of “home purchase loan” and “home improvement loan.” Also see the rule on multipurpose loans on page 12.

And from the FAQs

Refinancing --- line of credit. If a dwelling-secured line of credit satisfies and replaces another dwelling-secured obligation, is the line required to be reported as a "refinancing"?

Answer: No. A dwelling-secured line of credit that satisfies and replaces another dwelling-secured obligation is not required to be reported as a "refinancing," regardless of whether the line is for consumer or business purposes.



From your cite:

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

This says HELOCs that are for a home purchase or home improvement MAY be reported at the FI's option. It does not excuse the reporting of a HELOC that meets the definition of a refinancing, however the Q&A does.
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#1029297 - 08/27/08 07:02 PM Re: Reporting HELOCs on HMDA LAR Dan Persfull
CRAatBOK Offline

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Further South than I wanna be.
But the Q&A isn't address those people that chose to report lines of credit is it? I think it is saying that just because you have a loan that fits the definition of a refi that it doesn't have to be reported.
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#1029326 - 08/27/08 07:22 PM Re: Reporting HELOCs on HMDA LAR CRAatBOK
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
The Q&A gives the FI the option to report HELOC refinancings the same as the Reg gave the option for HP and HI. Therefore if you opt not to report them then you do not have to report any open-end lines of credit, but if you opt to report them then you report them all.
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#1029553 - 08/27/08 11:21 PM Re: Reporting HELOCs on HMDA LAR Dan Persfull
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
Then I guess we are agreeing???
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#1029721 - 08/28/08 01:24 PM Re: Reporting HELOCs on HMDA LAR CRAatBOK
RegsRfun Offline
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Floating in compliance land...
The official staff commentary to Regulation C, comment 4(a)(7)-3

"Loan amount—home-equity line. An institution that has chosen to report homeequity lines of credit reports only the part that is intended for home-improvement or home-purchase purposes."

If this is not correct, then I am confused.

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