Two questions:
According to Reg Z, Sec. 226.5b - requirements for home equity plans, that apply to open-end credit plans secured by the consumer's dwelling - section (d)(8)states that, "Fees imposed by third parties to open a plan: A good faith estimate, stated as a single dollar amount or range, of any fees that may be imposed by persons other than the creditor to open the plan, as well as a statement that the consumer may receive, upon request, a good faith itemization of such fees. In lieu of the statement, the itemization of such fees may be provided."

1.Our Mortgage department often does HELOCS along with a first mortgage and closes them at the same time. Will the GFE privided for the 1st suffice for the second as well, or does a whole separate disclosure of fees need to be given for the HELOC? If so, should the fees for appraisal and credit report be disclosed as "POC" because the client paid them in conjinction with the 1st?

2.If the bank pays the closing costs for stand-alone HELOCS, it sounds to me that the fees can be disclosed as a lump sum as long as we give the applicant a right to request a breakdown. If we do not give the applicant that right, do we need to disclose the fees even if we pay them? (In our case, the applicant must pay the closing costs if they or we terminate their line within 2 years.)
Thanks,
BC

1. GFEs are not required for HELOCs if you follow the Reg. Z disclosure requirement for them. Reg Z requires these to be given at the time an application is provided to the applicant. We disclose any POC as such in the final closing agreement.

2. Yes and yes. Again POC.