We are considering adding a credit card to acess HELOCs. What regs should be considered here? Is it just Reg Z? Would the credit card have to comply with the CARD Act even though it is only being used to acess the line? Are they considered two seperate products? Thanks.

My first comment is a question. Why does management want to do this to the bank?

Second here are some things that come to mind:

* Research applicable state law to determine whether advances through a card is not restricted.
* Regulation Z is your main federal consideration and probably also the biggest reason why you don't really want to do this. I'm talking about liability for unauthorized transactions. Usually HELOCs have a larger credit limit than other types of open-end consumer credit. Do you really want to have to refund money back to someone who has a fraudulent transaction(s) and reports the information to you to limit their liability? I encourage you to think long and hard about the fraud risk here.

1026.2(a)(15)

(ii) Credit card account under an open-end (not home-secured) consumer credit plan means any open-end credit account that is accessed by a credit card, except:

(A) A home-equity plan subject to the requirements of §1026.40 that is accessed by a credit card;