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#1065832 - 10/16/08 06:29 PM HELOC Increase
RegsRfun Offline
Junior Member
Joined: Feb 2008
Posts: 27
Floating in compliance land...
If a FI chooses to report HELOC, would an increase to the amount be reportable, if it is being used for HMDA purposes?

Thanks for your help!!

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#1065841 - 10/16/08 06:36 PM Re: HELOC Increase RegsRfun
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Is this a new loan (new loan replaces the old loan) or a modification (no new note legally)?
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David Dickinson
http://www.bankerscompliance.com

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#1065846 - 10/16/08 06:39 PM Re: HELOC Increase David Dickinson
RegsRfun Offline
Junior Member
Joined: Feb 2008
Posts: 27
Floating in compliance land...
Modification...so I know it wouldn't count as a refinance, but I wasn't sure if the new money, to be used for home improvement, should be reported?

Thank you!!

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#1065865 - 10/16/08 06:52 PM Re: HELOC Increase RegsRfun
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN

If you did not satisfy and replace the existing note with a new note then the "modification" does not meet the definition of a home purchase, home improvement or refinancing.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1065869 - 10/16/08 06:56 PM Re: HELOC Increase Dan Persfull
RegsRfun Offline
Junior Member
Joined: Feb 2008
Posts: 27
Floating in compliance land...
Thank You!!! That's what I thought, but several others disagreed. Thanks again!!

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