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#2245873 - 11/25/20 03:13 PM HELOC exempt or not?
Everest Offline
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Joined: Jan 2012
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I am wondering about how the regulation reads in regards to reporting HELOCs or not. It uses the word "either". I first assumed that if we did not have over 200 originated HELOCs for 2 consecutive years we were exempt, however I am now second guessing this.

(12) An open-end line of credit, if the financial institution originated fewer than 200 open-end lines of credit in either of the two preceding calendar years


We originated the following:
2019: 117
2020: 205
2021: do we report or still exempt??

Thanks.

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#2245879 - 11/25/20 03:36 PM Re: HELOC exempt or not? Everest
John Burnett Online
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John Burnett
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Your 2019 count means you are exempt for 2021. The word "either" means just what it says -- For 2021, if you originated fewer than 200 dwelling-secured open-end lines of credit in 2019 or in 2020, you are exempt.

For the rule to mean otherwise, it would have to say, "unless you originated 200 or more dwelling-secured open-end lines of credit in either of the preceding calendar years, you are exempt," or something similar.
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#2245882 - 11/25/20 03:47 PM Re: HELOC exempt or not? Everest
Everest Offline
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Joined: Jan 2012
Posts: 282
Thanks John, that makes sense.

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#2245893 - 11/25/20 05:24 PM Re: HELOC exempt or not? Everest
Comply 101 Offline
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Comply 101
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The calculation would include commercial or business purposes LOCs secured by a dwelling?
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#2245940 - 11/30/20 03:31 PM Re: HELOC exempt or not? Comply 101
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 308
Maine
Yes, the count would include commercial and business lines of credit.
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