Home equity loans are reportable if they are for a HMDA reportable purpose. Home Equity Lines of Credit are optional reporting.
In this mailing I will assume they have to return a "voucher" to obtain the loan. If they return this "voucher" and they indicate a purpose that is HMDA reportable then IMO they would be reportable, however there would be no GMI due to them being mail applications. Unless you meet with them face to face during the loan application process. See page D-13.
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The opinions expressed are mine and they are not to be taken as legal advice.