Posted By: jel99
HELOC - 03/09/22 07:07 PM
I have some conflicting opinions on some data points for HELOC's. This is my first year reporting HELOC's, so I apologize for any confusion.
1. Reporting HELOC's for the purpose of debt consolidation - It is my interpretation that we should be reporting consumer, other purpose HELOC's and report the line as other on the LAR. Is this correct?
2. GMI collection for HELOC's - We have not collected GMI on HELOC's in the past since they have not been HMDA reportable. It is my interpretation that all consumer HELOC's this year regardless of purpose, GMI must be collected.
1. Reporting HELOC's for the purpose of debt consolidation - It is my interpretation that we should be reporting consumer, other purpose HELOC's and report the line as other on the LAR. Is this correct?
2. GMI collection for HELOC's - We have not collected GMI on HELOC's in the past since they have not been HMDA reportable. It is my interpretation that all consumer HELOC's this year regardless of purpose, GMI must be collected.