I posted this in the incorrect HMDA forum so I am reposting here:
We do not report HELOC's. FOP customer comes in and applies for a HELOC (FOP= Friend of President). We received the application for HELOC, Early plan disclosures, booklet, etc., etc. are all given to customer within required timeframe. Customer later withdraws loan as they do not need the funds. I received the withdrawal packet from the loan officer along with the approval. A credit decision was made (approved) and the write up states that the product was initially for a HELOC and then the customer changed their mind and wanted a multiple-advance term loan (draw down line) and the loan purpose is ..........'may use funds to construct new primary dwelling or may use funds to purchase primary dwelling' smirk . Yes, that is the purpose written on the approval. I thought I was okay with not reporting it under HMDA as it was initially a HELOC but wasn't sure how to proceed since the customer changed their mind. Should I report this? Thank you.