We do not report HELOC loans on our LAR. However, it is my understanding that we should report a closed-end loan secured by a dwelling that was used to pay off an open-end loan secured by a dwelling. Am I correct?
How about the reverse situation - HELOC was originated and part of proceeds paid off a dwelling secured loan. If not reporting HELOC's would we report as a refi?
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Thanks for all of your help!