FRB FAQs-Do we have to report all HELOCs even if the borrower does not advance on the line of credit?

Compliance > Regulation C - HMDA > FRB FAQs
Q:  Do we have to report all HELOCs even if the borrower does not advance on the line of credit? For example, if the borrower intends to use $10,000 of a $30,000 HELOC for home improvement purposes but does not advance on the loan, does this loan need to be reported for HMDA?
 
A:  If the bank chooses to report HELOCs for HMDA, the bank should report all HELOCs intended for home improvement or home purchase purposes, even if the borrower does not advance on the line of credit. The HMDA LAR instructions included in Appendix A to Regulation C (HMDA instructions) explain that the bank should report only the portion of the HELOC intended for home improvement or home purchase purposes. The use of the word “intended” implies that the bank should report the line of credit even if the borrower does not actually advance on the funds as anticipated.

 

This can be found in - HMDA FAQ#7 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

 

Add Feedback