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#2270360 - 05/12/22 01:44 PM HMDA reportable but not for Open-end Collecting GM
Cbigun Offline
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Joined: May 2016
Posts: 158
I think I am still confused on what is allowed. If we are HMDA reportable, but not for Open-end Lines of credit and the Loan officer collects DI on the open end line and it is not for the purch/refi, are we in violation? The loan officers are so used to collecting for dwelling secured loans, they tend to forget and automatically collect for HELOCs.

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#2270388 - 05/12/22 05:37 PM Re: HMDA reportable but not for Open-end Collecting GM Cbigun
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,835
Bloomington, IN
From the OSI to 1002.13(b):

6. Inadvertent notation. If a creditor inadvertently obtains the monitoring information in a dwelling-related transaction not covered by ยง 1002.13, the creditor may process and retain the application without violating the regulation.

The loan officers are so used to collecting for dwelling secured loans, they tend to forget and automatically collect for HELOCs.

However if this is consistently happening among your originators then I would have to opine they are not "inadvertently" collecting the information and they are routinely collecting the information as part of their application process. In that case you have violations.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2270410 - 05/13/22 01:03 PM Re: HMDA reportable but not for Open-end Collecting GM Cbigun
Cbigun Offline
100 Club
Joined: May 2016
Posts: 158
Thank you.......... we have addressed it and you have solidified my thought.

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