HELOCs and 2018 Revised Reg C

1.) We understand for loans that are COVERED by current Reg C, we may begin collecting disaggregated information and not be in violation of Reg B. However, for loans that are NOT COVERED by current Reg C, is it a violation of Reg C and/or Reg B to gather disaggregated information?

2.) For reporting purposes, for loans that had an application date in 2017 and GMI was NOT COLLECTED with an action date in 2018, what would we report under the GMI fields? (N/A or Not Provided)

Welcome to BOL Kerri. I see this is your first post. Let me clarify:
1) Are you asking about a loan that is subject to Reg B's GMI collection requirements (purchase or refinance of a principal dwelling) yet exempt from HMDA - like a bridge loan?

2) If you take the application in 2017, you can collect GMI or Demographic Info. You can also report either in 2018, if the application was in 2017. You say GMI was not collected. Did you ask and they said "I do not wish . . ." or did you not request it?

David,

Thank you for responding.

1) Specifically we are asking about HELOCs. Currently we do not report HELOCs (except when the purpose is for home improvement) and GMI information is not collected. In anticipation of the 2018 HMDA changes, we would like to begin implementing system changes to collect the disaggregated GMI for HELOCs in 2017 that would not be reported until 2018 (depending on action date). So the question is, can we collect GMI information on HELOCs?

2) GMI was not requested.

Thank you for you help.

Kerri

HELOC's are NOT exempt from Reg B's requirement to collect GMI. If the HELOC is used to purchase/refinance the principal dwelling, you should be collecting GMI under today's rules. You don't report it on the HMDA LAR, however.

I haven't thoroughly read the new Reg B proposal that was released this week. Maybe someone else can respond with what the proposal says about collecting Demographic Info prior to 1/1/18 for HELOCs.

Any more thoughts on this one? I have the same question as Kerri in regard to HELOCs.

Today, we only collect GMI on HELOCs if we know the purpose is to purch or refi the customer's primary dwelling securing the HELOC (which is very rare). Today we do not ever report HELOCs on our HMDA LAR.

Let's say we get a HELOC app in Dec. 2017 and customer is not making initial advance to purchase or refi primary dwelling...they're just getting a HELOC to use when they want to. Then the HELOC doesn't close until Jan. 2018. We need to report the HELOC on our 2018 HMDA LAR, but we did not collect the GMI at application in 2017. Do we report "NA" for the GMI fields? Or do we collect the GMI information at (gasp) closing of the HELOC?