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#504285 - 02/24/06 05:27 PM Are we tired of HMDA yet?
t cochran Offline
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t cochran
Joined: Apr 2001
Posts: 57
Great Falls, MT
We have a commercial line of credit that is secured by a multi-family dwelling. Our bank does not report Home Equity lines of credit, but does this one fall through the cracks? Page C-3 in the HMDA Getting it Right book states:

Home-equity line of credit means an open-end credit plan secured by a dwelling as defined in Regulation Z.

Reg Z says a dwelling is 1-4 family.

Do I report or not? Would this be in the sane categirt as a Home Equity Line of Credit

Would it fit CRA?

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#504286 - 02/24/06 06:37 PM Re: Are we tired of HMDA yet?
bgehres Offline
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Joined: Mar 2005
Posts: 126
I wouldn't, the purpose is not to purchase, refi, or improve a dwelling.

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#504287 - 02/24/06 07:37 PM Re: Are we tired of HMDA yet?
Jaeger Schnitzel Offline
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Jaeger Schnitzel
Joined: Nov 2005
Posts: 315
Oregon
I wouldn't report it as a small business loan either. With multi-family RE securing the LOC, you'd have to call code it REMU, so it wouldn't qualify as a small business loan.
_________________________
You keep using that word. I do not think it means what you think it means.

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#504288 - 02/24/06 11:02 PM Re: Are we tired of HMDA yet?
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:

We have a commercial line of credit that is secured by a multi-family dwelling. Our bank does not report Home Equity lines of credit, but does this one fall through the cracks? Page C-3 in the HMDA Getting it Right book states:

Home-equity line of credit means an open-end credit plan secured by a dwelling as defined in Regulation Z.



But the FFIEC FAQ clarifies that ALL lines of credit are optional (business or consumer).
_________________________
David Dickinson
http://www.bankerscompliance.com

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