We do not report HELOC's for HMDA. However, had a question arise about a refi of a HELOC. If we take a HELOC balance to 0 and close that loan and open another HELOC (secured by same dwelling)this would be considered a refi, correct? In the Reg where it talks about optional reporting it states:

(3) Home-equity lines of credit made in whole or in part for the purpose of home improvement or home purchase.

It doesn't mention refi of HELOC so we wanted to verify if this was reportable or not? Any help is greatly appreciated.

We don't report HELOCs either. Doesn't matter for what purpose.

That's what we were thinking, but we didn't think it would hurt to double check. Thanks for your help!

this would be considered a refi, correct?

You will find your answer here:

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