We have three HELOC's in which we have done partial write-downs. This was while we were using a core processing system that supports shadow accounting. We are no on a new core processing system that does not have shadow accounting.

So, the first statement from the new system shows a much lower balance due to the write-downs.

Can we simply turn off their notices entirely, or since it is a comsumer product covered under Reg Z, will we have to maually create a bill each month?

I assume you have suspended the credit privileges on these account and that's why you are making this inquiry. If there is debit or credit activity on the account during the billing cycle you must provide a periodic statement. I'm not aware of any exception to exempt the periodic statement requirement because the credit privileges have been suspended.

The only "activity" has been late charges being assessed.

Does this mean that we need to provide a statement?

bump please

A posted late charge or finance charge would be a debit transaction thus making the account subject to the periodic statement requirements of 226.7.

I am being told that since they have a balance, we would need to send a statement, even if we turn off the late charges.

Is this true?

Yes. I see I forgot to include that little tidbit in my previous comments. If the account has an outstanding balance, a credit transaction or a debit transaction during the billing cycle a periodic statement must be furnished.

Since we do not have shadow accounting with our new core system, we are having a difficult time trying to figure out we are going to create bills manually each month.

Has anyone else ever had to do this? If so, if anyone has any spreadsheets or notes on the steps to take, that would be helpful.