[mdunker]

Due to the change in the number of HELOC and Open end secured by a residence we will not have to report the these loans. My question relates to the collecting of GMI since we will not have to report these loans are we required to collect GMI? If not is it permissible if we?

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[kowsley]

If you are exempt from reporting open-end LOCs due to not meeting the 500 threshold then you do not have to collect on any of the data fields associated with those types of loans. You may continue to report on them if you choose to under the new “optional” reporting requirements in the final rules (Paragraph 3(c)(12)-2) but if you do report you must report all such applications, origination’s, or purchases of open-end lines of credit. As far as collecting GMI, you don’t have to collect for it on these types of transactions since you are not reporting; however, if collecting GMI for underwriting purposes that would be acceptable without having to report.

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