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#1755491 - 11/06/12 04:51 PM HELOC & ROR for INCREASE OF FUNDS
Anonymous
Unregistered

Modification/Extension of HELOC. Purpose is the increase amount which is subject to ROR. Any other Regs apply?

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#1755523 - 11/06/12 05:34 PM Re: HELOC & ROR for INCREASE OF FUNDS Anonymous
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If the HELOC has not yet reached maturity then a change in terms/modification agreement will suffice. If it has matured then you must treat it as a new plan and provide all new disclosures.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1755569 - 11/06/12 07:04 PM Re: HELOC & ROR for INCREASE OF FUNDS Anonymous
Anonymous
Unregistered

thanks a million!!!

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#1760418 - 11/23/12 05:46 PM Re: HELOC & ROR for INCREASE OF FUNDS Anonymous
clmartin Offline
New Poster
Joined: Jan 2012
Posts: 9
Thanks, Dan. So no need for re-issusing the same initial disclosures when a customer wants to increase their line?

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#1760571 - 11/26/12 02:43 PM Re: HELOC & ROR for INCREASE OF FUNDS Anonymous
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If you are modifying the HELOC before its maturity date then new disclosures would not be required, however rescission would apply to the increase in the credit limit.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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