I went the HMDA help route back in January. It went like this:
My question to HMDA Help :
Would you please clarify:
We opt not to report home equity lines of credit. Does this option only include the consumer product by that name, or also include business lines of credit?
Second, does it make any difference if they are open end or closed end business lines of credit?
The first response :
All products that are considered lines of credit are optional reporting for HMDA. However, if you report any lines of credit, you must report all lines of credit.
Open end lines of credit are optional for reporting under HMDA. Closed end loan applications are required to be reported under HMDA.
Thank you for using HMDAHELP.
Due to the reference to closed end loans, I countered with:
Regarding open end versus closed end credit lines, we offer the typical open end line that can be advanced, paid down and advanced again which is clearly optional reporting under HMDA. The closed end lines are basically draw loans, where the disbursements can not be readvanced. The maximum loan amount can be reached only once. But they are still written as business lines of credit. They are NOT fully disbursed at closing like a typical closed end loan. Are those optional for reporting?
The next response was :
Thank you for the details. A closed-end line of credit would be HMDA-reportable assuming that it meets HMDA guidelines (HMDA purpose definitions).