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#2112348 - 12/28/16 05:38 PM Not HMDA reportable for 2017 BUT
AZloan Offline
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Joined: Apr 2016
Posts: 266
From reading the new HMDA rule, our bank is not HMDA reportable for 2017 data collected. Starting 2018, HELOC is HMDA reportable. Is this right to understand that if we originate 100 HELOCS in the previous 2 years (2017, 2018), we have to report in 2019? What if we originate 50 HELOCs in 2017 that point, I know I won't be HMDA reportable in 2019 even if we originate 100 or more 2018. Do I still collect the GMI information in 2017? in 2018? I am trying to wrap my brain around this "go back 2 year rule" along with when I need to collect GMI

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#2112352 - 12/28/16 05:54 PM Re: Not HMDA reportable for 2017 BUT AZloan
AZloan Offline
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Joined: Apr 2016
Posts: 266
Or do I just have to collect GMI information on my HELOCs regardless of we end up reporting or not?

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#2112368 - 12/28/16 06:43 PM Re: Not HMDA reportable for 2017 BUT AZloan
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If we originate 100 HELOCS in the previous 2 years (2017, 2018), we have to report in 2019?
Correct.

What if we originate 50 HELOCs in 2017 that point, I know I won't be HMDA reportable in 2019 even if we originate 100 or more 2018.
Correct.

Do I still collect the GMI information in 2017? in 2018?
No and No - for HMDA. If the HELOC's are subject to Reg B's ยง1002.13(a) (purchase/refinance principal dwelling), then you would collect GMI for that purpose, but not report it on your LAR as your not subject to HMDA.

Or do I just have to collect GMI information on my HELOCs regardless of we end up reporting or not?
No. Over collection of GMI is a violation of Reg B.

IF you became subject to HMDA in later years, you then start collecting GMI (it will be called "Demographic Information" in 2018) on applications RECEIVED in that year. IOW, you don't need to collect GMI on an application now because you might be subject to HMDA next year.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2112370 - 12/28/16 06:54 PM Re: Not HMDA reportable for 2017 BUT AZloan
AZloan Offline
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Joined: Apr 2016
Posts: 266
Thank you for the clarification David. I greatly appreciate it.

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