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.