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#2263905 - 12/21/21 09:24 PM Reporting HELOCs for first time in 2022
JoAnne S Offline
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Joined: Aug 2020
Posts: 8
We will be reporting HELOCS for the first time beginning 1/1/2022. For applications which began in 2021 do we need to be collecting all the data at the time of application in 2021 even though we haven't been reporting HELOCs prior to 2022?

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#2263911 - 12/21/21 10:51 PM Re: Reporting HELOCs for first time in 2022 JoAnne S
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,935
Galveston, TX
You could under 1002.5(a)(4)(iv).
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#2263922 - 12/22/21 03:07 PM Re: Reporting HELOCs for first time in 2022 JoAnne S
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 407
You can in 2021, and I believe you'd have to have it for applications taken in 2021 and action taken in 2022.

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