One area we see confusion with over and over again is use of the term “line of credit”. There are many banks that refer to a multiple advance, closed-end transaction (such as a construction loan) as a line of credit. This isn’t necessarily wrong, but it can cause a lot confusion when you start to consider the compliance implications. For example, Regulation Z and HMDA define a “line of credit” as being open-end (meaning a borrower can draw the money, pay it back, and draw it again – like a HELOC). HMDA coverage and reporting are driven by both closed-end “loans” and open-end “lines”. If you are counting closed-end loans as lines because that’s the terminology your bank uses, you are setting yourself up for problems.
Do you want to learn more about which institutions and applications are covered by HMDA? Be sure to join us for our HMDA Transaction Coverage webinar on April 17, 2018!
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!