LOC Secured by Residence: HMDA Reportable?

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Question:

Our borrower, a partnership, has a business line of credit which is secured by the primary residence of one of the partners. Is this HMDA-reportable?

Answer:

Open-end lines of credit are optional reporting transactions whether they are for a business or consumer purpose.

Closed-end draw notes would be reportable if the loan's purpose meets the definition of a home purchase, home improvement or refinancing defined in Regulation C Section 203.2.

First published on BankersOnline.com 2/28/11