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#619278 - 09/28/06 03:26 PM Reg B - Collecting Monitoring Information
Amos Offline
100 Club
Joined: Nov 2004
Posts: 237
USA
I have a loan application for a home equity line of credit ("HELOC"). The HELOC will be secured by the applicant's current principal dwelling. The purpose of the HELOC is to purchase a new principal dwelling. My bank is not a HMDA reporter. I did not request government monitoring information because the HELOC is not secured by the new principal dwelling being purchased, but my compliance person is indicating I should have requested it. I would appreciate any thoughts on whether or not I should have requested the monitoring information. Thanks!

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Lending Compliance
#619279 - 09/28/06 03:41 PM Re: Reg B - Collecting Monitoring Information
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,025
Bloomington, IN
No you should not have.

Sec. 202.13 Information for monitoring purposes.

(a) Information to be requested—(1) A creditor that receives an application for credit primarily to purchase (or to refinance a home purchase loan) a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, shall request as part of the application the following information regarding the applicant(s):
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#619280 - 10/01/06 10:58 PM Re: Reg B - Collecting Monitoring Information
Lucy Griffin Offline

Diamond Poster
Lucy Griffin
Joined: Nov 2000
Posts: 1,544
The HELOC is really a bridge loan which would not be subject to monitoring data collection.

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