We have a Commercial Line of Credit that we are taking the owner's PR as collateral taken as Abundance of Caution; is there any HMDA reporting that needs to be done?

Yes, if it meets the HMDA definition. Ignore the ABC aspect since it has no impact on whether or not it's reportable

Depends on the purpose of the loan.

1. Open-end LsOC are optional reporting.
2. Does the loan's purpose meet the definition of a home purchase, home improvement or refinancing?

Thanks Fan and Dan!

Dan,

Are you saying that all lines of credit are optional reporting?

From my understanding, a line of credit has to be subject to Reg Z to qualify for the "optional reporting". We have farm operating lines secured by dwellings that we are reporting every year as refi's because I didn't think they met the HELOC definition according to HMDA.

From the Q&A;

Refinancing --- line of credit. If a dwelling-secured line of credit satisfies and replaces another dwelling-secured obligation, is the line required to be reported as a "refinancing"?

Answer: No. A dwelling-secured line of credit that satisfies and replaces another dwelling-secured obligation is not required to be reported as a "refinancing," regardless of whether the line is for consumer or business purposes.

Business purpose loans are not subject to Reg. Z.

Is that in the FFIEC Q&A?

I hadn't seen that before.

You'll find the Q&A at the following link:

http://www.ffiec.gov/hmda/faqreg.htm