Skip to content
BOL Conferences
Thread Options
#1089926 - 12/01/08 09:34 PM Home Equity Program Disclosure
Cale_N_Oats Offline
Platinum Poster
Cale_N_Oats
Joined: Aug 2008
Posts: 742
Southern Illinois
I was reviewing our program disclosure and noticed that it didnt contain one of the things that is required according to Reg Z:

b)The time which an application must be submitted to obtain the specific disclosure terms?

Can someone explain why this is required and how i can state it on my disclosure?
_________________________
Serenity Now!!!

Return to Top
Lending Compliance
#1090070 - 12/02/08 01:44 PM Re: Home Equity Program Disclosure Cale_N_Oats
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,673
Bloomington, IN
You only have to make that disclosure if it is applicable.

226.5b(d)

Content of disclosures. The creditor shall provide the following disclosures, as applicable:


The reason for the disclosure is to avoid a "bait and switch" scenario. IOWs if you are running a promotional program and the terms of that program are only good for 120 days then you must inform the applicant by when they must apply to receive those disclosed terms.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#1090079 - 12/02/08 01:50 PM Re: Home Equity Program Disclosure Cale_N_Oats
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Ours doesn't read exactly like that, however it does say

that if any of the terms (other than the APR) change prior to closing that they could cancel and any charges would be refunded.

(Not exact wording, but close!)
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1090109 - 12/02/08 02:17 PM Re: Home Equity Program Disclosure RR Joker
Cale_N_Oats Offline
Platinum Poster
Cale_N_Oats
Joined: Aug 2008
Posts: 742
Southern Illinois
RR Joker, thats what ours says as well, thanks to both of you.
_________________________
Serenity Now!!!

Return to Top

Moderator:  Andy_Z