Just wanted to clarify, regular lines of credit are option HMDA. For example, the business lines of credit we do (open-end) would be optional reporting.

I know the HMDA books says Home Equity Lines of Credit, but I wanted to be sure this was all lines of credit.

Thanks!

Interesting you raise this question because I had a similar question. Since it's along the sames lines, I hope if you don't mind if I post it here along with yours.

My question assumes that business lines of credit (used to purchase mobile homes) are reportable, so I was wanting to know what Date Action Taken to use for every subsequent draw request down the road for mobile home purchases. Do we use the date the business line of credit was approved for EVERY subsequent draw request or do we use the date of each request for the Date Action Taken, or is there another answer I'm not thinking of?

If you choose not to report lines of credit, you don't report any revolving lines, including the ones for business purposes.

Glutes, if your line is revolving, and you report lines, you would only report the first advance. If it's a guidance-type line of credit, and individual notes are issued for each advance, you would report each note.

I concur with hmdagal's answer.

Excellent! Thanks for your repsonses Gal and Dan!

Would you be so kind as to provide the citation on where lines of credit reporting are optional?

Thanks in advance!

Pg 8 in the GIR book talks about Transactions to be Reported. Under HELOCs, there is no distinction between lines originated in the retail or commercial areas of the bank.

And from the HMDA FAQs at the FFIEC Websit:

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.

This is what I referred to as well but I read it differently:

Home equity lines of credit (HELOCs) for home purchase or improvement may be reported at the institution's option. Report only the amount that is intended for home purchase or home improvement purposes. An institution that reports home equity credit line originations must also report any applications that do not result in an origination.

I am reading that HELOC's are optional with respect to reporting. I don't believe the business line of credit in my example above is considered a HELOC (am I incorrect in this assessment?). Therefore, I took the position that the business line of credit for dwelling "purchases" MUST be reported. If this is indeed optional, I'd love to stop reporting these, but I don't believe the GIR guidance above qualifies my example as meeting the "optional" requirement. Could this be answered or addressed elsewhere?

Also, where is the guidance on the Date of Action taken for a business line of credit if we are reporting these?

Thanks again!

Thanks Dan. This was the only thing I could see in the FAQ's as well. This only answers a question about a dwelling secured line of credit with respect to the "refinancing" loan purpose. It doesn't touch on the other the loan purposes, such as "purchase".

Wouldn't it be nice if they just did away with HMDA altogether? In 9 years, I haven't received ONE SINGLE INQUIRY from the general public about our HMDA disclosure data, or even HMDA in general. The ONLY request or interest in our HMDA reporting information have been the examiners.

As I interpret the Q&A, although it is in reference to a refinancing, it is saying that a dwelling secured line of credit does not loose its optional reporting exemption simply because it meets the definition of a refinancing. Therefore why would a dwelling secured line of credit lose its optional reporting exemption for other loan purposes such as home purchase or home improvement?