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#1374357 - 04/15/10 12:19 AM REG B and HELOC reinstatement
Marnie Offline
Gold Star
Joined: Nov 2007
Posts: 437
Nevada
We have taken steps regarding our HELOC's by implementing a program to evaluate these based on collateral value and evaluate across the board to ensure unbiased review. Just so you know, we have covered every aspect in our policy based on recent guidance regarding reductions of home equity line limits. Based on collateral criteria set in our policy for this, we curtail the limits and send them a letter to that extent, telling them they can request a reinstatement, which would generally involved a full blown appraisal.

1st question: since we curtailed and have told them they need to request a reinstatement of the limit, would we be bound by REG B timing requirements? I know this is not a new application, but it is unique in that they have to request re-evaluation from us. My instincts tell me we should be adhering to the 30 days and notification requirement just as a best practices procedure, if not wholly due to regulation. Thoughts anyone?

2nd question: are we obligated to give them a copy of the appraisal? Again, my instincts say yes, but need confirmation.

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Lending Compliance
#1374977 - 04/15/10 09:21 PM Re: REG B and HELOC reinstatement Marnie
Marnie Offline
Gold Star
Joined: Nov 2007
Posts: 437
Nevada
BUMP--anyone?

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#1375084 - 04/16/10 12:35 PM Re: REG B and HELOC reinstatement Marnie
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
1. Yes. They are applying for additional (reinstatement of) credit.

2. IMO yes. Again they have applied for additional (reinstatement of) credit.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1375743 - 04/16/10 07:50 PM Re: REG B and HELOC reinstatement Dan Persfull
Marnie Offline
Gold Star
Joined: Nov 2007
Posts: 437
Nevada
Thank you.

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