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#790720 - 08/07/07 06:38 PM purchase money HELOCs
#1hogfan Offline
100 Club
Joined: Mar 2005
Posts: 105
Arkansas
Does government monitoring information need to be collected on a purchase money HELOC that is for the borrowers primary residence? I appreciate your help.

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Lending Compliance
#790767 - 08/07/07 07:21 PM Re: purchase money HELOCs #1hogfan
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,535
Bloomington, IN
See the Commentary to 202.13

.....An application for an open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1686994 - 04/09/12 06:10 PM Re: purchase money HELOCs #1hogfan
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
Found this old thread and have a related question. This section reads "or refinancing of a principal dwelling." The request in question is a refinance of a purchase money HELOC. The Reg B monitoring information was collected on the original request. It has now matured and is to be "refinanced". However as this is a revolving credit and the line may have been used for other "purposes" after the original purchase, would this still be a refinance of a purchase? The collateral is the principal dwelling so if I'm reading this correct, it doesn't matter how the line was used after the purchase, it's more about the refinance of the dwelling and Reg B is applicable. Am I overthinking this? Thank you.

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