Skip to content
BOL Conferences
Thread Options
#1741340 - 09/17/12 03:19 PM HELOC Account Opening Disclosures
Confused Again Offline
Junior Member
Joined: Apr 2010
Posts: 26
Our HELOC product requires an automatic payment to obtain the disclosed rate, which is an index plus a margin of -.25%. In our disclosures we indicate the preferred rate will increase by 1%, including the floor rate, if automatic payments are discontinued.

In the agreement/disclosure under Current Rates...we list the Margin Added to Index as .750%, rather than -.25%. I am told this is done to disclose the highest possible margin. We also list a 6% floor (rather than the 7% it would be without the preferred rate).

This doesn't seem right to me. Am I just confused? Or should we be disclosing the margin as -.25% - which it will be unless the customer discontinues their automatic payment?

Return to Top
Lending Compliance
#1741365 - 09/17/12 04:06 PM Re: HELOC Account Opening Disclosures Confused Again
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Answered in the private forums.....
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z