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Our bank started HELOCs about 10 years ago and they are starting to mature. I was asked if we need to collect GMI when we start to refinance these. I said yes using the regulation and the definition of refinancing.
(1) A creditor that receives an application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling….
6. Refinancings. A refinancing occurs when an existing obligation is satisfied and replaced by a new obligation undertaken by the same borrower.I am getting some push back. Am I look at this wrong?
Thanks!
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