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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 LOC and CIT
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#2155112 - 11/28/17 07:07 PM LOC and CIT
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
We will be reporting lines of credit for HMDA under the new rules. Currently we report lines for CRA. Under CRA we also report change in terms that increase the credit limit.

Under HMDA will we ever need to report a change in terms? At first I didn't think so, but what if we open a LOC and then increase the credit limit in the same reporting year?

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#2155142 - 11/28/17 07:59 PM Re: LOC and CIT Bville
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
If you increase the credit limit using a modification agreement the transaction would not be reportable.

If you increase the credit limit with a new loan agreement that satisfies and replaces the existing loan agreement it would be reportable.
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The opinions expressed are mine and they are not to be taken as legal advice.

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