§__.12(j) – 2
Q: May a home equity line of credit be considered a “consumer loan” even if part of the line is for home improvement purposes?
A2. If the predominant purpose of the line is home improvement, the line may only be reported under HMDA and may not be considered a consumer loan. However, the full amount of the line may be considered a “consumer loan” if its predominant purpose is for household, family, or other personal expenditures, and to a lesser extent home improvement, and the full amount of the line has not been reported under HMDA. This is the case even though there may be “double counting” because part of the line may also have been reported under HMDA.
Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016