Q: In determining whether the bank reports a HELOC for HMDA purposes, does the bank need to consider denied, withdrawn and approved but not accepted HELOCs into the threshold of 200?
A: The count is based on the number of open-end lines of credit that the bank has originated.
Reference:
Section 1003.3(c)(12) provides that an open-end line of credit is an excluded transaction if a financial institution originated fewer than 500 open-end lines of credit in either of the two preceding calendar years.
Comment 1 to § 1003.3(C)(12): https://www.consumerfinance.gov/rules-policy/regulations/1003/3/#3-c-12-Interp-1
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