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#2278185 - 11/23/22 04:48 PM Re: Unsecured Line/Cross Collateralized with a 1-4 fam Cat Lover
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 83,628
Galveston, TX
I am going to try one more time.

If, on or after November 7, 1989, a security interest in the consumer's dwelling is added to a line of credit entered into before that date, the substantive restrictions of this section apply for the remainder of the plan, but no new disclosures are required under this section.

Therefore. if line of credit was entered into after that date, new disclosures are required.

That is the end of the story for me. If you cannot seem to understand the concept that if there is a statement in a regulation that says, "if then, you do not need to do this" and you cannot seem to grasp the fact that sort of statement means that "if not, you do need to do this", then you are really going to struggle at this compliance profession.
The opinions expressed here should not be construed to be those of my employer:

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Lending Compliance
#2278926 - 12/17/22 05:52 PM Re: Unsecured Line/Cross Collateralized with a 1-4 fam rlcarey
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
So, if it's temporary financing under HMDA, then you do not need to report it, but if it is not temporary financing, then you do need to report it?

C'mon RL, we both know Compliance is more complex than that.

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