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#112150 - 09/04/03 05:17 PM HMDA and Adverse Action
complyguy Offline
Gold Star
Joined: May 2001
Posts: 494
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!

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Lending Compliance
#112151 - 09/04/03 06:01 PM Re: HMDA and Adverse Action
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 80,383
Galveston, TX
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.
The opinions expressed here should not be construed to be those of my employer:

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