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#1723790 - 07/26/12 06:04 PM Fixed Rate HELOC
notuntermywatch Offline
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Joined: Jun 2006
Posts: 392
MN
Are there any issues with lowering the rate on a fixed rate HELOC at the customers request? Can we just execute using a CIT?

I've looked at Reg Z open end rules and since it is reducing the finance charge it appears to be okay, but just wanted another opinion.

Thanks

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Lending Compliance
#1723804 - 07/26/12 06:25 PM Re: Fixed Rate HELOC notuntermywatch
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
An existing open-end credit can be modified through a written agreement with the borrower without triggering additional disclosures.
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