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#1311352 - 12/22/09 04:23 PM Closed-end LOC -- HMDA?
In Need of Help 101 Offline
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Joined: Jan 2006
Posts: 574
This subject of LOC and HMDA always confuses me. We do not report HELOCs at our bank. Is it true that if you do not report HELOCs you do not report any LOC?

If not what about this loan scenario? Consumer borrows money to rehab his home from fire damage. We are doing a closed-end LOC for one year. At the end of the one year we will term out the balance of the LOC.

HELP!!!

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#1311400 - 12/22/09 04:58 PM Re: Closed-end LOC -- HMDA? In Need of Help 101
Dani York, CRCM Offline
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Dani York, CRCM
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TN
I'm not an expert and I've been out of the HMDA loop for a little bit, but this seems like temporary financing to me, and would be reportable once termed out if the LOC and the term out are secured by a dwelling.
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#1311422 - 12/22/09 05:07 PM Re: Closed-end LOC -- HMDA? Dani York, CRCM
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Quote:
Is it true that if you do not report HELOCs you do not report any LOC?


Yes, but the LOC option in HMDA refers to open-end lines of credit.

Draw notes, such as the one described, are reportable unless they qualify for another exemption such as temporary financing.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1311449 - 12/22/09 05:21 PM Re: Closed-end LOC -- HMDA? Dan Persfull
In Need of Help 101 Offline
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Posts: 574
Do you consider this scenario temporary since we will be converting this to a term loan once it matures or rehab is complete?

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#1311733 - 12/22/09 08:13 PM Re: Closed-end LOC -- HMDA? In Need of Help 101
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
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Central City, NE
Yes. What you describe is temporary financing as it will be replaced by a loan of a longer term.
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