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#1387597 - 05/07/10 02:45 PM Statements required on all open-end loans?
complofcr Offline
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Is a monthly statement required on all open-end loans, even those not secured by real estate? We have several unsecured personal lines of credit that currently get a monthly interest payment notice, but I think we should be sending them a monthly statement. We send statements on our HELOC & ODP lines.

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#1387611 - 05/07/10 02:52 PM Re: Statements required on all open-end loans? complofcr
ahou Offline
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ahou
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Yes, if there is a deb or cr bal more than $1 or if a fin chg is imposed, you must send a mthly stmt and the credit is open-end of any kind.
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#1387625 - 05/07/10 03:00 PM Re: Statements required on all open-end loans? ahou
Dan Persfull Offline
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Bloomington, IN
Quote:
Is a monthly statement required on all open-end loans,


No. However a periodic statement is required. The periodic statement (billing period) can be monthly, bi-monthly, quarterly, semi-annually or even annually. And they must meet all the disclosure requirements in 226.7 and its Commentary.

Although monthly periodic statements are the most common they are not required.
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#1387776 - 05/07/10 05:04 PM Re: Statements required on all open-end loans? Dan Persfull
4newt Offline
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Dan, Please clarify. Our open-end personal credit lines are not tied to a credit card and are not home equity lines of credit. Must the periodic statments be in the new format as of 2/22/10 if all points are covered?

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#1387778 - 05/07/10 05:06 PM Re: Statements required on all open-end loans? 4newt
4newt Offline
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part 2.... each section seems to refer to a "card issuer" or "credit card account" and ours is not a credit card account.

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#1387821 - 05/07/10 05:35 PM Re: Statements required on all open-end loans? 4newt
ahou Offline
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ahou
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Originally Posted By: jnewton
Dan, Please clarify. Our open-end personal credit lines are not tied to a credit card and are not home equity lines of credit. Must the periodic statments be in the new format as of 2/22/10 if all points are covered?


Certain disclosures on the periodic statement must be grouped together as stated in 226.5(a)(3)(iv) and 226.7(b)(13) for non-cr cards/non HELOCs. Fees & int imposed have to be grouped together, in prox to transactions, substantially similar to model G-18(A). I'm sure I don't have to tell you, but it is very complicated to read. smile
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#1387842 - 05/07/10 05:55 PM Re: Statements required on all open-end loans? 4newt
Dan Persfull Offline
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Bloomington, IN

Sec. 226.7 Periodic statement.


The creditor shall furnish the consumer with a periodic statement that discloses the following items, to the extent applicable:



Periodic statements for open-end credit is governed by 226.7 and its Commentary. You will need to review this section and determine which sections apply to your personal line of credit. But regardless all open-end credit must be provided a periodic statement if there is an outstanding balance, a debit transaction or a credit transaction that took place during the billing cycle. The interval of the statements are governed by your legal contract.
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#1387989 - 05/07/10 07:49 PM Re: Statements required on all open-end loans? Dan Persfull
4newt Offline
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East Texas
fine, fine, fine.....you people just want to make me cry on a Friday!! Thankfully our software provider is on the ball. No worries. (i hope)

Thanks for your input.

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#1388002 - 05/07/10 07:58 PM Re: Statements required on all open-end loans? 4newt
Trees Offline
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Do we also have to re-arrange the info presented on HELOC periodic statements as well??? I keep harping on this one because I keep reading about rules not out yet on HELOCs....I am particularly interested in knowing if we need the grouping and/or tablular format or.....can we just wait until the HELOC rules come out. We have all the goodies already on the statements, not in the fancy format needed for the other open credits....

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#1388017 - 05/07/10 08:10 PM Re: Statements required on all open-end loans? ahou
swiggles Offline
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Originally Posted By: ahou
Certain disclosures on the periodic statement must be grouped together as stated in 226.5(a)(3)(iv) and 226.7(b)(13) for non-cr cards/non HELOCs. Fees & int imposed have to be grouped together, in prox to transactions, substantially similar to model G-18(A). I'm sure I don't have to tell you, but it is very complicated to read. smile


I know. I finally gave up. I'm not going to do anything. cry I through threw my books across the room yesterday. They are still on the floor.
Last edited by swiggles; 05/07/10 08:12 PM.
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#1388032 - 05/07/10 08:19 PM Re: Statements required on all open-end loans? Trees
Raquel Offline
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Look at section 226.7(a) as published in the Federal Register of 2/22/2010. Other than a re-numbering of the requirements, there is not a significant change from what is currently required. However, it does say that the creditor may at its option change to 226.7(b) which is where the table, grouping, etc. are listed.

If your HELOC statement meet the Z requirements now, it appears that they will after 7/1/2010 also. Of course, your processor may want to change all open-end statements to the same format.

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#1388037 - 05/07/10 08:20 PM Re: Statements required on all open-end loans? swiggles
4newt Offline
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Amen to that. And my hair is sticking out in all different directions! So much for TRYING to comply!

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#1388059 - 05/07/10 08:33 PM Re: Statements required on all open-end loans? 4newt
swiggles Offline
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Originally Posted By: jnewton
Amen to that. And my hair is sticking out in all different directions! So much for TRYING to comply!


I can top that! I no longer have any hair as I have snatched myself bald over this.
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#1388086 - 05/07/10 08:46 PM Re: Statements required on all open-end loans? swiggles
4newt Offline
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East Texas
LOL!!

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#1389171 - 05/11/10 06:07 PM Re: Statements required on all open-end loans? swiggles
QCL Offline

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QCL
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NW IL
Originally Posted By: swiggles
Originally Posted By: ahou
Certain disclosures on the periodic statement must be grouped together as stated in 226.5(a)(3)(iv) and 226.7(b)(13) for non-cr cards/non HELOCs. Fees & int imposed have to be grouped together, in prox to transactions, substantially similar to model G-18(A). I'm sure I don't have to tell you, but it is very complicated to read. smile


I know. I finally gave up. I'm not going to do anything. cry I through threw my books across the room yesterday. They are still on the floor.


I am still at this point... cry - but also, I am sitting on the floor with the books. We learned from our Core Processor that our ODP statements will now need to be seperate from the checking statement for programming reasons. But I am wondering WHEN was this supposed to be done by? Was this due 2/22?
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#1389207 - 05/11/10 06:40 PM Re: Statements required on all open-end loans? QCL
ahou Offline
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ahou
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Assuming that your ODP is a open-end credit line product, July 1st is the compliance date for stmts.
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#1389276 - 05/11/10 07:43 PM Re: Statements required on all open-end loans? ahou
tickledpink Offline
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Joined: Feb 2006
Posts: 37
Under the Card Act 226.7(b)(11) - (13) should be implemented by 2/22/10. Does the late payment warning fall under that date or is it effective 7/1/10? Obviously this is for credit cards periodic statements.

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