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#1517880 - 03/04/11 07:38 PM HELOC
KMCB Offline
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Joined: Dec 2010
Posts: 43
WI
Im terming a HELOC into a second mortgageno new money, no new mortgage. The customer did get a rescission since we are taking it from a revolving to a installment loanis it HMDA reportable?

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#1517884 - 03/04/11 07:41 PM Re: HELOC KMCB
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
This would be reportable as a refinance as you had to redocument the note and give new disclosures to convert to a term.

It is a refi as it is dwelling secured replacing dwelling secured to same borrower.
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#1542831 - 04/28/11 06:04 PM Re: HELOC Kathleen O. Blanchard
1995Banker Offline
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Joined: Apr 2002
Posts: 241
Is it the same for a HELOC (w/p&I pmts) being refinanced to another HELOC (w/interest ony pmts). We do not report HELOC's, but in this case would it be HMDA reportable? Thanks!
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#1542899 - 04/28/11 06:40 PM Re: HELOC 1995Banker
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
A HELOC that is refinanced into a HELOC is still optional reporting. IOW, the exemption overrules the "refinance" reporting requirement.
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#1543672 - 04/29/11 07:54 PM Re: HELOC David Dickinson
1995Banker Offline
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Posts: 241
Great! Thanks so much David!
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#1543921 - 05/02/11 01:17 PM Re: HELOC 1995Banker
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
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#1545259 - 05/04/11 01:46 PM Re: HELOC Dan Persfull
1995Banker Offline
100 Club
Joined: Apr 2002
Posts: 241
Thanks to you too Dan!
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