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#186168 - 05/03/04 04:54 PM Triggering Term open end home equity line?
cle Offline
100 Club
Joined: Jan 2004
Posts: 161
Home Equity Line of Credit
Rates from Prime to Prime + 3.50% *
Rate based on loan to value %
Call ____________.

* Is the above index considered a rate triggering term?

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Lending Compliance
#186169 - 05/03/04 05:37 PM Re: Triggering Term open end home equity line?
Anonymous
Unregistered

I'd say yes. The Commentary to 226.16(b) includes implicit terms in the description of triggering terms. So since you can readily determine APRs from this information, I'd say all the disclosure information is needed.

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#186170 - 05/03/04 07:16 PM Re: Triggering Term open end home equity line?
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
One comment without looking at the advertising regs: Stating a loan to value implies a specific down payment. With some regulators that will be deemed a triggering term.
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