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#1510088 - 02/15/11 12:48 AM HELOC Program Disclosures
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
Must the HELOC Program Disclosure contain verbiage regarding possible negative amortization if the program DOES NOT contain the ability for negative amortization.

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Lending Compliance
#1510105 - 02/15/11 04:31 AM Re: HELOC Program Disclosures Princess of Power
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
No.

5b(d)(9) Negative Amortization

1. Disclosure required. In transactions where the minimum payment will not or may not be sufficient to cover the interest that accrues on the outstanding balance, the creditor must disclose that negative amortization will or may occur. This disclosure is required whether or not the unpaid interest is added to the outstanding balance upon which interest is computed. A disclosure is not required merely because a loan calls for non-amortizing or partially amortizing payments.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1510252 - 02/15/11 04:27 PM Re: HELOC Program Disclosures rlcarey
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
Thank you Randy ~ that has been my understanding as well, now to "politely" let my young OCC contractor examiner know he is mistaken.

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