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!

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 HELOC is really a bridge loan which would not be subject to monitoring data collection.