{"id":2386,"date":"2021-02-25T17:09:18","date_gmt":"2021-02-25T17:09:18","guid":{"rendered":"https:\/\/albanknews.com\/?p=2386"},"modified":"2021-02-25T18:13:23","modified_gmt":"2021-02-25T18:13:23","slug":"compliance-qa-heloc-hmda","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2386","title":{"rendered":"Compliance Q&A: HELOCs & HMDA"},"content":{"rendered":"

Q: <\/strong>In determining whether the bank reports a HELOC for HMDA purposes, does the bank need to consider denied, withdrawn and approved but not accepted HELOCs into the threshold of 200?<\/p>\n

A:<\/strong> The count is based on the number of open-end lines of credit that the bank has originated.<\/p>\n

Reference:<\/p>\n

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.<\/p>\n

Comment 1 to \u00a7 1003.3(C)(12): https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1003\/3\/#3-c-12-Interp-1<\/a><\/p>\n

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