We do not report our HELOCs to HMDA and are not close to the 200 for two consecutive years status but we were wondering:
1) is it permissible to start reporting them? I don't know the reason why we never reported them but I'm not sure how it would look to auditors/examiners if we started reporting them when we have not met the required threshold.
2) are there any pros and cons of reporting vs not reporting HELOCs?

The cons include that even if you voluntarily report, you are held to the reporting accuracy standards.

I thought of that along with training the loan officers to start collecting more data on this product. Which means more data for our file review staff to look at (we QC every loan).
Thanks for your reply.

The other consideration is that if you do not anticipate crossing the reporting threshold within the next year, make sure you are allowed to collect the Demographic Information under Regulation B 1002.5(a)(4).

That was one of the items I was wondering about. We don't collect it now, but will have to once we start reporting. We have already made the decision when they lowered the number of loans from 500 to 200, that once we start reporting we will continue report even if there is a year that we don't originate 200 or more to avoid saying this year we collect it and next year we don't. I'm pretty sure one of the HMDA classes I attended said we could start collecting GMI in 4Q of the year prior to mandatory reporting and those loans would not be considered a violation. Based on our numbers we've got a ways to go before we even reach 200. I'm trying to gather as must information as I can for the person that is taking over HMDA when I retire next year as to what they need to be watching for.