Re: HMDA – reimbursements and RLOC


The first loan does not appear to be for home purchase, home improvement or for refinance, and therefore is not HMDA reportable.

When Regulation C refers to lines of credit it refers to Home Equity lines of credit subject to Regulation Z. Apparently your line of credit is not covered by Regulation Z, so there is no direct discussion of this product in Regulation C. But the guidance for lines of credit states that reporting of lines of credit is optional, and if reported, only the portion that is for home purchase or home improvement is reported. If you choose to report, report that portion of the line that the borrower indicates at application is for home purchase or home improvement.