Answer:
It is important to understand that the open-end threshold and reporting requirement does not apply only to HELOCs. Open-end dwelling secured consumer lines that are not secured by the consumer’s dwelling, and thus technically not HELOCs, must be counted as well as business purpose open-end lines of credit secured by dwellings that are for the purpose of a dwelling purchase, refinance or cash-out refinance, of home improvement.
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Learn more about Kathleen Blanchard’s webinar HMDA – Thresholds, Exemptions, Temporary, Partial – How It All Works
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