Fair Housing - Disclose Assets/Net Worth

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Question:

Is it necessary under fair housing to disclose assets/net worth? The question has been raised that we must input all customer asset information on HELOC applications to give an accurate net worth for fair housing. Any lender I have ever worked with has never done this.

Answer:

Unless this is a safety and soundness related request/suggestion from your regulator, there is only one regulatory requirement for the applicant's asset and net worth information to be obtained and recorded. If the financial institution is regulated by the OCC, the application is for the refinance of the applicant's principal residence and is secured by that residential real property (see 12 CFR 27.2 for definitions), then the applicant's total assets and net worth must be obtained and recorded (12 CFR 27.3(b)(xvii). This section is sometimes fondly referred to as the "27 points of light".

First published on BankersOnline.com 10/27/08