I'm filling in at another department today & don't have access to my reference materials, but my CEO needs an answer.

Situation: Customer has a $50K HELOC. Requests a $175K mortgage (max. indebtedness $225K). Based on appraisal, max indebtedness can't exceed $205K. Bank is willing to go $180K on the mortgage if the HELOC is cut to $25K.

Questions: If customer accepts the $180K mortgage w/the $25K reduction in the HELOC, is the mortgage approval all that is recorded on the HMDA-LAR? Is the reduction in the HELOC the only thing that is noted on the adverse action? Am I asking the wrong questions? Your answers and constructive correction are appreciated!

Regarding the HMDA question, I think the answer is yes. I don't see where there is adverse action involved if the customer is agreeing to the arrangement. It's an acceptance of a counter-offer and would not be considered adverse, even if you reducing the amount available under the HELOC.