On the other hand, if the HELOC terms provide for a prepayment period after the draw period has ended, the arrival of that prepayment period is not a refinance event, and disclosures aren't required if the repayment period was properly disclosed at inception of the extension of credit. This assumes that the terms provided in the HELOC loan agreement will be used, with no changes.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8