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Government Monitoring Info on 2nd Home HELOCs

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Question: 
D​o bankers collect government monitoring information on 2nd home HELOC​s​?
Answer: 

It would depend on a number of factors.

Under Regulation B, not normally, unless the funds where being used to purchase a primary dwelling .

Official Interpretation

1002.13(a) Information to be requested.

5. Transactions not covered. The information-collection requirements of this section apply to applications for credit primarily for the purchase or refinancing of a dwelling that is or will become the applicant's principal residence. Therefore, applications for credit secured by the applicant's principal residence but made primarily for a purpose other than the purchase or refinancing of the principal residence (such as loans for home improvement and debt consolidation) are not subject to the information-collection requirements. 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.

Under HMDA, if you exceed the limit and are required to report lines of credit, then yes.

1003.3(c) Excluded transactions. The requirements of this part do not apply to:

(12) An open-end line of credit, if the financial institution originated fewer than 500 open-end lines of credit in either of the two preceding calendar years; a financial institution may collect, record, report, and disclose information, as described in §§ 1003.4 and 1003.5, for such an excluded open-end line of credit as though it were a covered loan, provided that the financial institution complies with such requirements for all applications for open-end lines of credit that it receives, open-end lines of credit that it originates, and open-end lines of credit that it purchases that otherwise would have been covered loans during the calendar year during which final action is taken on the excluded open-end line of credit;

First published on 09/09/2018

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