We have only just begun reporting HELOC transactions to our HMDA LAR and a question has come up surrounding Lender Credits and Recording Charges. First if a $500.00 Lender Credit is given on all HELOC transactions a line item credit, i.e. Portion of Appraisal, Title, Credit ect. Should it be shown as a lender credit or should the total fees simply be reduced by fee paid by the bank. Secondly should recording charges be excluded from a total loan cost as they are on a closed end transaction that would take the cost from Line D?
Both open-end and closed-end loans are reported on your HMDA LAR. However the LAR field that requires reporting of lender credits only applies to transaction subject to TRID, section 1026.19 of Regulation Z. HELOCs are open-end credit and are not subject to TRID, therefore the lenders credits on a HELOC are not reported on your LAR.