Are HELOCs subject to section 32?

Asked by: Larry Schmidt  |  Last update: January 1, 2026
Score: 4.9/5 (75 votes)

But there are two other consumer mortgage products that also enjoy the same exemption: ground-up construction loans and home equity lines of credit (“HELOCs”) that are higher-priced (Section 35) but not high-cost (Section 32).

Which of the following are exempt from section 32 regulations?

Exempt from the Section 32 designation are: reverse mortgages; construction loans financing the initial construction of a new dwelling; loans originated and financed by a Housing Finance Agency; and.

Are HELOCs subject to Safe Act?

The SAFE Act includes HELOCs. (1007.102). However, the SAFE Act does not mandate which documents the MLO number is to appear on. Reg Z (1026.36(g) identifies the Loan Documents that the MLO number must appear on under the Loan Originator rules.

Are HELOCs subject to HMDA?

Home equity lines of credit (HELOCs) may not be in the data even if intended for home improvement or home purchase because reporting HELOCs is optional. Additionally, not all mortgage lenders are HMDA reporters.

Are HELOCs subject to HOEPA?

HOEPA generally covers the following loan types (primary residences): Purchase mortgages. Refinances. Home equity lines of credit (HELOCs) and home equity loans.

NMLS Exam - Section 32 of TILA: Home Ownership Equity Protection (HOEPA)

35 related questions found

What loans are not subject to HOEPA?

Loans Exempt from HOEPA Coverage
  • Reverse mortgages.
  • Construction Loans (applies to only the initial construction of a new dwelling)
  • Loans originated and directly financed by Housing Finance Agency (HFA)
  • Loans originated under the U.S. Department of Agriculture (USDA's) Rural Development Loan Program.

Are HELOCs subject to ECOA?

Both the ECOA and the FCRA have adverse action requirements that may apply when a creditor suspends a HELOC or reduces the credit limit because of a significant decline in the value of a property.

Are HELOCs subject to respa?

In general, RESPA's servicing rules do not apply to HELOCs whenever the Act or rule uses the term “mortgage loan.” The duty to provide a transfer of servicing statement, the 60-day ban on late fees, and the 60-day safe harbor for payments sent to the old servicer do not apply to HELOCs.

Are HELOCs HMDA reportable bankersonline?

Since my original post I found this in the FDIC's 2013 HMDA Guide: "Home equity lines of credit (HELOCs) for home purchase or home improvement may be reported at the institution's option.

What regulation covers HELOCs?

Occasionally, we receive questions about the disclosures necessary for home equity lines of credit (HELOCs). HELOCs are interesting, as they are open-end lines of credit governed by Subpart B of Reg Z, but also have their own rules under section 1026.40.

Are HELOCs subject to TRID?

The TRID Rule applies to most types of mortgage loans. Mortgage loans to which the TRID Rule does not apply include HELOCs, reverse mortgage loans, or mortgage loans secured by a mobile home or dwelling that is not attached to real property.

Are HELOCs exempt from HPML?

Therefore, if it is a HELOC, it's exempt from HPML as Dan said. Sec. 226.5b Requirements for home equity plans.

Are HELOCs federally regulated?

Home equity loans can be issued by both banks and credit unions, and by several other financial institution types—and each is regulated by a different body. Code of Federal Regulations. “12 CFR Part 226 — Truth in Lending (Regulation Z).” U.S. Congress.

What is considered a section 32 loan?

The mortgage would be a Section 32 loan if certain fees and points, including the mortgage-broker fees, that borrowers pay at or before closing exceed $547 (2007 amount) or 8 percent of the total loan amount, whichever is larger.

What is the difference between section 32 and section 35 loans?

Section 35 (1026.35) (Higher-Priced Mortgage) Exempts All Bridge Loans (see discussion above. Section 32 (1026.32) (High-Cost) Owner-Occupied Rules Apply to Because there is No Exemption for Loans to Acquire a New Principal Dwelling.

What fees are included in section 32?

* Points and fees to be included in the 8% calculation: - Prepaid finance charges, such as loan fees, points, origination fees, escrow fees, maintenance fees, and application fees. - All compensation paid to brokers, either by the borrower or the lender.

Do HELOCs get reported to HMDA?

The 2015 HMDA Rule requires some financial institutions to report data on certain dwelling-secured, open-end lines of credit, including home-equity lines of credit. Prior to the 2015 HMDA Rule, Regulation C allowed, but did not require, reporting of home-equity lines of credit.

Are home equity lines of credit considered residential mortgage loans under the Safe Act?

“Residential mortgage loan” means any loan primarily for personal, family, or household use that is secured by a mortgage, deed of trust, or other equivalent consensual security interest on a dwelling (as defined in Section 103(v) of the Truth in Lending Act, 15 USC Section 1602(v)) or residential real estate upon ...

Are line of credit loans HMDA reportable?

Home purchase loans, home improvement loans, and refinancing loans are all types of loans that apply to HMDA reporting requirements. The loan must also be either an open-end line of credit or a closed mortgage loan to qualify for HMDA reporting.

Does the QM rule apply to HELOCs?

For closed-end, high-cost HOEPA loans, you must comply with the ATR/QM rule. Because the ATR/QM rule does not apply to HELOCs, the HOEPA rule requires that you consider a member's: Current and reasonably expected income or assets; and.

Are HELOCs subject to the right of rescission?

You don't have the right to rescind a mortgage you initially used to buy a home, but you can exercise this right for HELOCs, home equity loans and refinances.

Do HELOCs have a closing disclosure?

If you are applying for a HELOC, a manufactured housing loan that is not secured by real estate, or a loan through certain types of homebuyer assistance programs, you will not receive a HUD-1 or a Closing Disclosure, but you should receive a Truth-in-Lending disclosure.

What types of loans are not HMDA reportable?

If the loan or line of credit is neither a closed-end mortgage loan nor an open-end line of credit, the transaction does not involve a covered loan, and the financial institution is not required to report information related to the transaction.

Are HELOCs subject to Regulation Z?

Reg Z HELOCs (Open-End Credit) Explains the Regulation Z requirements for home equity lines of credit, including disclosures, changes in terms, and periodic statements.

Why are HELOCs not subject to TRID?

HELOCs are open-end credit and are not governed under the TRID regulations. You need to be delivering an early HELOC disclosure under 1026.40 and not an LE.