We have several borrowers who are having financial difficulties and we would like to modify their HELOCs into fixed-rate term loans. I know Reg Z says closed-end disclosures have to be given when open-end loans are converted to closed-end, but I'm wondering if there is a different place I should be looking because the loans would be made at the borrower's request to get a manageable payment. In some cases, the HELOCs have been modified previously to make them interest only but now that time period has elapsed. In other cases, the HELOCs are evergreen and have no specific repayment phase or maturity date. In still others, the HELOCs have matured. If the borrowers agree to the modifications, are we ok to go ahead with them - and do we still need closed-end disclosures?
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