I have searched to try and get a feel for should you "classify" HI loans, collect GMI and report or not. I think I have a handle on what constitutes "classifying" the loan but I can't get a feel for the pros and cons of doing it or not. Do they give us this "out" due to possible system limitations (not being able to call the data back up easily for these loans)? Do the majority of banks stay away from classifying and reporting these? Not that we get a ton of car or unsecured loans where the purpose is home improvement - but I'm trying to prepare for any eventuality.

Like I said in my subject, new at the HMDA side and I appreciate any info you can offer.

Basically, IMHO - there are no pros, there are only cons. If you don't classify, you don't report, therefor you can't skrew up the reporting.

I'll give you my two cents: my philosophy is--don't report any loans for HMDA that i don't have to....therefore, since we don't meet the "internal classification" criteria, we don't report non-dwelling secured HI loans. If you don't either, personally, i wouldn't change anything in that regard (not classifying them). I mean...it's cut and dried in the sense of ...if you don't classify them as HI internally, don't report them....but it sounds like you might be contemplating STARTING to classify them as HI internally, and if that's your thinking, i wouldn't. Obviously...just my thoughts.

Or what Randy said.

Thank you both for your responses. That's the way I was leaning with everything I have read but wanted to be sure I wasn't missing anything (already decided a big no on HELOC's). Anyway, as a new reporter your insight is very helpful!