I understand that HELOCs are applicable to the requirements of the Fair Housing Act. In reviewing some of our HELOC applications I've discovered that some of the required information is lacking.....number of residential units, number of years applicant has been employed in his/her present line of work, proposed monthly housing payment, purchase price, race/national origin, sex.....is all of this required to be on a home equity loan application?

We utilize the HELOC Application from Bankers Systems. Thanks.

Bump.....Can anyone help me with this? Thanks.

It's been a while since I reviewed the Fair Housing Act, but I didn't think the information you inquired about is a requirement of the Fair Housing Act. The Act deals with housing discrimination based on the prohibitive factors of race, color, national origin, religion, sex, familial status and disability. Basically Reg. B plus 2.

Who is your primary Federal regulator? If it is the OCC, look at 12 CFR Part 27. There is a discussion of a Fair Housing application/inquiry register. I'm not regulated by the OCC so I am not too familiar with this.

The OCC is our primary regulator....12 CFR Part 27 deals with the Fair Housing Act Home Loan Data System which we are not required to do since we are subject to HMDA reporting. So do any of the Fair Housing Act requirements apply to our bank (since we are subject to HMDA)??

Be sure you read 27.3(b) - I believe that applies regardless of whether you are a HMDA reporter.

The Fair Housing Act definitely applies to your bank, but that act does not have any specific recordkeeping requirements that I know of.