I would like to tag in on this conversation. We are planning a HELOC promotion. We plan to advertise this as a "No Closing Costs". We do indicate in our Terms and Conditions that if the loan is paid off during the first 3 years, the borrower is responsible for paying back 3rd party fees such as Drive By Appraisal, Title Abstract, Flood Search, Annual Tax Service, etc., etc..
Under the Reg. can we advertise this as "No Closing Costs"?