Please forgive me for asking this question, but I have been in training for our imaging system all week and am experiencing the old "CRS" disease. I know there are a few instances when a loan request could fall under HMDA and not ECOA for monitoring purposes (home improvement loan, reportable loan secured by 1 to 4 family, but not owner occupied...), but what about ECOA purposes and not HMDA.

Thanks in advance - I know this is a compliance 101 question, but I am fried.

Hopefully I'm accurate on this.... Reg C does not require you to report prequals on the HMDA LAR, but, applications under Reg B would trigger an Adverse Action Notice (if applicable).

Example...an institution does not report HELOC's (no GMI for HMDA), but makes a new HELOC paying off an old HELOC (refinance under ECOA, GMI required).

If I'm wrong, I'm sure an expert will chime in.

Bank doesn't report HELOCs for HMDA / HELOC done to purchase primary residence would require GMI.

Thanks again for the info!!!

Another possibility where GMI would be required under Reg B but not under Reg C would be a particular type of bridge loan. If the bridge loan is to fund the purchase of the primary dwelling, and secured by that dwelling , then GMI would be required under Reg B but not under Reg C since bridge loans are exempt under Reg C as "temporary financing (such as bridge or construction loans)."

Thanks for the refresher Dan...been looking at BSA/CIP for a while.

Too many regs, too little time

-arye (also too lazy to log in )