We routinely indicated "personal investments and expenses" for HELOCs
HELOCs are secured by real property therefore they are not subject to BSA purpose statement requirement.
Before you accept generic purposes such as "personal expenses" you may want to review the following 2007 Email to my bank's President.
You know how I have always harped on the loan officers not getting a specific purpose for the loan request? That personal, business etc. was not sufficient. You might find the following interesting. This bank was fined $250,000 for violations of the Bank Secrecy Act. Not properly obtaining a specific loan purpose was one of the citations.
This it the legal document: http://www.occ.treas.gov/FTP/EAs/ea2007-011.pdf
This is a summary:
/12/2007 - The International Bank of Miami, N.A.
CMP: $250,000 Agencies: OCC Assets 9/30/06: $807 million
The International Bank of Miami, N.A., Coral Gables, Florida, is alleged to have violated the Bank Secrecy Act; to have engaged in unsafe and unsound practices when it failed to supervise adequately its Capital Markets Group (CMG); and to have failed to ensure that CMG's securities transactions were conducted safely, soundly, and legally. Specifically, the OCC's order alleges that the bank:
â€¢ Violated the BSA and 31 CFR 103.33(a) [records of loan transactions] by permitting CMG to maintain records that frequently failed to adequately identify a legitimate business purpose for loans, or fully and adequately describe the nature and purpose of loans (loans were described merely as being for "working capital").
â€¢ Failed to maintain a system of controls to monitor and report suspicious activity.
â€¢ Failed to adequately identify and monitor accounts of politically-exposed persons (PEPs).
â€¢ Failed to monitor loans accounts and payments for suspicious activity.
â€¢ Did not have an adequate training program on detecting and reporting suspicious activity.
â€¢ Permitted CMG to make loans that did not conform to the bank's own lending policies, and to omit obtaining proper authorization for large credits.
â€¢ Allowed CMG to provide incomplete or inadequate loan documentation and recordkeeping, not in accordance with bank policies.
â€¢ Failed to do adequate customer due diligence, especially for high-risk customers.
â€¢ Allowed CMG to maintain an inadequate record of its securities transactions.
â€¢ Permitted OMG to engage in securities transactions in violation of OCC regulations.
â€¢ Allowed CMG to conduct securities transactions with high-risk countries without risk management procedures.