I just had a conversation with our vendor. He made an excellent point (and it was quite a "duh" moment for me...):
If we change the due dates on the HELOC's, we're going to have contractual issues to deal with (not to mention more account maintenance). The easier alternative is simply to have our billing date be earlier. So if we move our billing date and mail statements on the 23rd, we can keep the due date at the 15th and not encounter so much maintenance.
Is anyone else going down this path, or are most of you changing the due dates?
I am not the only one thinking this!! yeah!!!
We are not changing due dates either, since they are due daily (30 days from loan closing).
We are just adjusting our lead time from 10 days to 25 (plus the 10 days 'grace' mandated by the state
). We will have to do some manual billing, but this seems far easier than adjusting due dates.
Unless I am missing something
By the way, in listening in on a conference call with our vendor today as well, I am getting the impression that many people do not understand the definition of a 'grace period' in this new legislation. It has some very clear meanings, and limitations that many of us have not traitionally associated with a grace period. I encourage everyone to review the definition and the examples given to determine if they have a true 'grace period' in place.
Also, in the same call with the vendor, the vendor was making the some statements that the examiners are not going to be prepared to review for this, that they will most likely not be concerned if we have missed the dealine as long as we have a plan in place to comply within the next cycle or two. I found this to be very dangerous, not only on the part of the vendor, but for anyone thinking this as well. My understanding is, per the rule and opinions, that if you are not ready to comply on the 20th of August your only recourse is to refrain from
any negative penalties being assessed against your customer, or reporting them negative in any fashion. Maybe just me, but I do not see any wiggle room in this.