When our customers are at loan closing for the purchase of their home, our loan officers want to provide them with a Home Equity Line of Credit. They want to use the home purchase application and credit bureau from the home purchase.

I applaud them for being innovative, but the compliance side of me sees red flags.

Isn’t there a HELOC application we are required to use?

They also must give the initial program disclosure and the “When your home is on the Line” booklet at application. (At loan closing of the home purchase?)

There is also the Right of Rescission, Flood Determination, and Right to Receive Copy of Appraisal.

What if the customer doesn’t want the HELOC? What documentation needs to be done since they really didn’t apply for the HELOC, but we offered it to them?

ANY advice would be greatly appreciated.

There really isn't any reason not to do this, as long as you do it right. You've identified the significant issues I can see.

The regulation really doesn't address how or when to provide the application disclosures if there is no application per se. My recommendation would be to provide the HELOC application disclosure at the time you solicit the customer for the HELOC.