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#1515141 - 02/26/11 01:04 AM Open-end credit - HELOCs
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
I need assistance with the following:

226.7(a)(4) Periodic rates. (i) Except as provided in paragraph (a)(4)(ii) of this section, each periodic rate that may be used to compute the finance charge, the range of balances to which it is applicable,

We don't vary our periodic rates based on purchases, cash advances, and so on. So, my question is this: are we required to disclose each periodic rate for the balance at that time if a change in rate occurs?

For example:

$25,000 at 5.5% Jan 1 - Jan 21
$25,000 at 6.0% Jan 22 - Jan 31

We don't do this now, however, if the bank chooses to do so, i want to be sure i undersand that each periodic rate for the balance at the time of rate change must be disclosed on the periodic statement.

I don't think our vendor can provide it - so hopefully, it won't come to pass...thanks in advance.

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Lending Compliance
#1515176 - 02/27/11 01:12 PM Re: Open-end credit - HELOCs Tryin-2-Comply
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
Yes, if you change your rate mid-cycle, you would be required to disclose them both.
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#1515252 - 02/28/11 03:06 PM Re: Open-end credit - HELOCs rlcarey
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
Thank you for your reply - I appreciate your help.

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