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GMI for a Home Equity Loan if Not HMDA Reportable?

Question: 
If you are not HMDA reportable, do you have to collect GMI for a Home Equity Loan? Not a refinance of purchase money, strictly home equity to consolidate miscellaneous consumer debt and medical bills.
Answer: 

by Randy Carey: You would then fall under the Regulation B collection rules: An application for an open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling.

Answer: 

by Jim Bedsole: The original poster said Home Equity Loan, not Home Equity Line of Credit, some I'm presuming it is closed end, not open end, but Randy's comment still applies. Collection of GMI under Reg B would only be required if the primary purpose of the loan is the purchase or refinance of a principal dwelling. The original post sounds like that is not the primary purpose so GMI collection is not required. In fact, collection of GMI information on that loan would constitute a fair lending violation unless it was exempt under provisions of 12 CFR 1002.5(a)(4).

First published on 09/30/2018

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