Question:

Hi Heather,

Quick question… 

We helped a member earlier this year with a reduction of his HELOC interest rate.  An application was completed to ensure that he qualified for the reduction, but a new loan was not completed in our host system.  Do we need to submit a HMDA filing for this application? 

Answer: No.  A request for a rate reduction on a current HELOC would not meet the definition of “application” in Reg C, which is, “an oral or written request for a covered loan.”