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#1516383 - 03/02/11 05:03 PM HELOC fees
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
According to the periodic statement transactions sample G-18(A) there are two blocks in which fees and interest must be segregated.

I want to make sure i understand this correctly.

1. Fees section: Late payment fee, over the limit fee, balance transfer fee, returned payment fee, termination fee,

2. Interest charged - this one has me confused because it references "finance charge" as defined as those in 226.4(b) - so in the interest section of the statement are we required to include all fees defined as a finance charge: interest, loan fees, inspection fee (after closing) service, transaction fee or activity fee. (we currently do not charge any fees on HELOCs but are going to start charging - so, I just want to be sure i understand this fully.)

3. the new fees and interest charged sections: are they rquried to be placed in a specific area on the HELOC statement? It appears at the end of the transactions is fine.

You're help is greatly appreciated....

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Lending Compliance
#1516938 - 03/03/11 03:16 PM Re: HELOC fees Tryin-2-Comply
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
I still need help with this if anyone has any ideas??? thanks.

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#1517415 - 03/03/11 09:41 PM Re: HELOC fees Tryin-2-Comply
bay7272 Offline
Junior Member
Joined: Dec 2010
Posts: 33
Indiana
On a HELOC periodic statement you can go by 226.7 (a)(6) or (b)(6). Since you mention G-18(A) I assume your using (b)(6). Interest is only finance charges attributable to periodic interest rates.

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#1517488 - 03/03/11 11:56 PM Re: HELOC fees bay7272
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
Finance charges can affect the APR (periodic rate) - thus, my reason for thinking it could include finance charges other than interest.

Look at 226.7(b)(6)(ii) - then, look at the definition of a finance charge under 226.4(b). Since other fees can affect the APR - this is where i am.

Maybe i am thinking about this way toooo much; but feel i'm on the right track with this.

So, if i'm thinking way to hard - someone please stop the insanity!!!!!

Thanks.

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#1519026 - 03/08/11 09:23 PM Re: HELOC fees Tryin-2-Comply
complygirl Offline
Platinum Poster
Joined: Oct 2004
Posts: 822
midwest
I have a HELOC periodic statement question as well. We currently disclose a "summary of account activity" section which discloses prev and new balance, advances and payments, an interest summary and a fee summary. Within the fee summary it discloses "fees financed", but no where on the statement does it specifically stated "finance charge". We don't charge fees on HELOCS (other than an origination fee at the time the account is opened). Is this statement item required to be disclosed as "finance charge" instead of "fees financed"? Maybe I'm splitting hairs here, but I just want to make sure we're in compliance with the statement requirements. Any feedback is appreciated.

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