Any more thoughts on this one? I have the same question as Kerri in regard to HELOCs.
Today, we only collect GMI on HELOCs if we know the purpose is to purch or refi the customer's primary dwelling securing the HELOC (which is very rare). Today we do not ever report HELOCs on our HMDA LAR.
Let's say we get a HELOC app in Dec. 2017 and customer is not making initial advance to purchase or refi primary dwelling...they're just getting a HELOC to use when they want to. Then the HELOC doesn't close until Jan. 2018. We need to report the HELOC on our 2018 HMDA LAR, but we did not collect the GMI at application in 2017. Do we report "NA" for the GMI fields? Or do we collect the GMI information at (gasp) closing of the HELOC?
Compliance - A Painful Addiction
All comments are mine & should not be taken as legal advice.