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Including Taxes/Insurance as Expenses for HELOC

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Question: 
We know that HELOCs are exempt from 12 CFR 1026.43. Our borrower is applying for a HELOC. He has four residential properties which he owns and is paying the taxes and insurance on these. None of these are his primary residence nor are they investment properties. The taxes and insurance are not on the borrower’s filed tax return . Do we need to include the taxes and insurance for these other non-primary residence real estate properties as expenses when qualifying the borrower for a HELOC?
Answer: 

Outside of 1026.43 - what bank does not make sure that someone can sufficiently meet all of their debt and other continuing obligations when they make someone a loan? That is safety and soundness 101.

First published on 07/28/2019

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