Jim Bedsole
Is the line of credit secured by a dwelling? If so, it may be HMDA reportable. There are too many variables to that to give you a clear answer on that front without knowing more facts about the transaction. If not secured by a dwelling, unless the line of credit is classified as a home improvement loan by your institution, it would not be HMDA reportable.
Dan Persull
Borrower will purchase and rehab properties with his own money and will come to lender to recover 75% of the costs of purchase and rehab.
These transactions are to replenish your borrower's funds, not to purchase a dwelling. These transactions will not be reportable based on the above statement.