HMDA Reporting & Closed End Home Equity Loans

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Question:

Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...

Answer:

This Real Estate Matrix can be found at http://www.bankerscompliance.com/downloads.htm .

A loan secured by a home that is not for purchase, home improvement or the refinancing of either, is NOT HMDA reported. For instance, a loan to purchase a car, pay off credit cards, etc. secured by a home should NOT be reported on the bank's HMDA LAR.

That is why the matrix splits out home equity loans from home improvement loans and HELOCs.

First published on BankersOnline.com 09/16/02