Are these HMDA loans?

Marketing just informed me they are doing a 25,000 non-customer mailing. It is going to say they are preapproved for a home equity loan. It is only conditioned on the fact that nothing material changes in their credit between the receipt of the letter and the funding of the loan.
We aren't saying what they can do with the $.

Since we don't know whether they were going to purchase a home with this $ do we have to report them on the LAR?

OR if they use the loan for home improvement then we would get the LAR information for an approved / funded home improvement loan with no preapproval code since it is not purchase. Right?

Do you report any of your other home eqity loans? If you report one, you have to report them all.

Check out the FFIEC's website and get a copy of HMDA - Getting It Right. It has everything you need.

Home equity loans are reportable if they are for a HMDA reportable purpose. Home Equity Lines of Credit are optional reporting.

In this mailing I will assume they have to return a "voucher" to obtain the loan. If they return this "voucher" and they indicate a purpose that is HMDA reportable then IMO they would be reportable, however there would be no GMI due to them being mail applications. Unless you meet with them face to face during the loan application process. See page D-13.

They are not lines of credit. We don't report our LOCs.
My concern was that all of them would be reportable as part of a preapproval program. But since preapproval are only reported for purchases and we don't know if these are purchases until the customer brings in the voucher I guess we are ok. We would obtain the GMI at that time. Thank you for the help.

Quote:

---

My concern was that all of them would be reportable as part of a preapproval program.

---

Not IMO. The applicant did not request the pre-approval.