I have some conflicting opinions on some data points for HELOC's. This is my first year reporting HELOC's, so I apologize for any confusion.

1. Reporting HELOC's for the purpose of debt consolidation - It is my interpretation that we should be reporting consumer, other purpose HELOC's and report the line as other on the LAR. Is this correct?

2. GMI collection for HELOC's - We have not collected GMI on HELOC's in the past since they have not been HMDA reportable. It is my interpretation that all consumer HELOC's this year regardless of purpose, GMI must be collected.

1) Generally yes, but it depends if it will be paying off any dwelling secured debt, in which case it would be a refi. Also remember it's not primary purpose, it's a waterfall (purchase, refi, HI, other). If it's $5K for home improvement and 40K for debt consolidation, it would be home improvement (assuming no dwelling secured debt being paid off).

2) If it's reportable, you should be collecting Demographic Info in accordance with Appendix B regardless of purpose.