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HMDA HELOC: Demographic Information Collection

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  • #37842
    AuddyD
    Participant

    In a scenario where the same applicant applies for both a Residential Mortgage loan and also a HELOC (simultaneous), should a demographic sheet be collected (is it required) for both loans or can just 1 be used and relied on for HMDA reporting?

    #37856
    kboatwright
    Participant

    Regulation C (HMDA) requires institutions to report lending data to their supervisory agencies on a loan-by-loan and application-by-application basis by way of a “register” reporting format. Based on this direct requirement, I would say you do have to collect the information at the time of application for each of the loans.

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