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#216908 - 07/28/04 08:11 PM Right of Offset / HELOC credit card
Anonymous
Unregistered

Anyone have an opinion whether the prohibition against the right of offset of Reg Z 226.12(d) applies to a HELOC with credit card access method (unless a separate pledge of the depsoit account is made)?

The Commentary to 226.12(d) is confusing, making it sound as though such a HELOC would qualify as a "credit card plan."

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Lending Compliance
#216909 - 07/28/04 08:55 PM Re: Right of Offset / HELOC credit card
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Previous discussion .

FWIW, I agree you lose your right to set off if the HELOC has card access.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#216910 - 07/28/04 10:01 PM Re: Right of Offset / HELOC credit card
redsfan Offline
Power Poster
redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
FWIW, so do I. Believe me that didn't make my bankers here any too happy, either.
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