HELOC application to replace a HELOC that had matured, both loans are secured by the primary dwelling . The balance of $29,000 of the matured HELOC will be paid off with the new HELOC, which in my mind qualifies as a refinance of a primary dwelling known at application. The credit limit will be $40,000 and it is not known what the additional funds after the $29,000 will be used for. That being said, I still think that we need to collect GMI because it was known at application it was readily apparent to the creditor that the primary purpose of the line is for the purchase or refinancing of a principal dwelling. (1002.13(a)(5))
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