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#1926967 - 05/28/14 02:18 PM Sweep from dda to heloc
MyScamper Offline
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Joined: May 2006
Posts: 452
Between here and there
I am wondering if anyone is familiar with a HELOC product that would sweep funds from a dda above a target amount, and apply as payments to the HELOC. What special disclosures would I need? What special limitations would I need to be aware of? Would Reg E come into play?

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#1926981 - 05/28/14 02:31 PM Re: Sweep from dda to heloc MyScamper
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
It would be a contractual issue. I see no specific compliance issues. The transfers would be exempt from certain parts of Regulation E - ยง 1005.3(c)(5).
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1927007 - 05/28/14 02:55 PM Re: Sweep from dda to heloc MyScamper
MyScamper Offline
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Joined: May 2006
Posts: 452
Between here and there
My concern specifically is if the client wants a debit card with the DDA. If he uses the debit card for a POS transaction that advances the HELOC, does this then become a credit card, subject to all their rules and regulations?

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#1927029 - 05/28/14 03:21 PM Re: Sweep from dda to heloc MyScamper
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Well that is a totally different question than you first proposed as there is no mention of a debit card or advances in your first post. However, the debit card transactions would remain subject to Regulation E. See 1026.13(i).
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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