Purchase money HELOC - HMDA reportable?

Posted By: Mike E

Purchase money HELOC - HMDA reportable? - 09/15/09 02:58 PM

Our Bank currently reports HMDA data on fixed rate/fixed term 2nd mortgages and NOT on HELOC's. However, we are seeing an increase in requests for "piggy back" HELOC's either with our own Mortgage dept or with other lenders. Are we required to report HMDA on purchase money 2nd HELOC's closing in conjuntion with another first mortgage or when closing in conjunction with another first when it is a refinance?
Posted By: hmdagal

Re: Purchase money HELOC - HMDA reportable? - 09/15/09 03:00 PM

No. If you have chosen to not report HELOC's, you don't report any of them.