Your advice is accurate…the following is a quote during a HELOC discussion that I heard from another forum in 2018:
“You are mixing acronyms between FNMA and HMDA, which is never a good idea.
If you are making a credit decision based on a HCLTV for FNMA – that equates to a CLTV under HMDA. It is purely the ratio upon which you are relying. How you get to that ratio is a moot point.”