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#2100401 - 09/26/16 07:02 PM HELOC-no fees if bank account & auto pay can we do
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
We currently offer two HELOC products one with a prepayment penalty up to 3 years and no fees, the other is fees with no prepayment penalty.. we are looking to add another option... no fees, no prepayment option but must have auto-pay out of bank account.

My thought is no you cannot tie accounts in this manner. however, I can't remember the rule.. any help is appreciated.

Thank you

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Lending Compliance
#2100482 - 09/26/16 11:23 PM Re: HELOC-no fees if bank account & auto pay can we do Chocaholic
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,907
Galveston, TX
You can do whatever is legal in your State.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2100527 - 09/27/16 02:53 PM Re: HELOC-no fees if bank account & auto pay can we do Chocaholic
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
The Commentary to ยง1005.10(e)(1) states:
Creditors may not require repayment of loans by electronic means on a preauthorized, recurring basis. A creditor may offer a program with a reduced annual percentage rate or other cost-related incentive for an automatic repayment feature, provided the program with the automatic payment feature is not the only loan program offered by the creditor for the type of credit involved.
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David Dickinson
http://www.bankerscompliance.com

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#2100613 - 09/27/16 06:40 PM Re: HELOC-no fees if bank account & auto pay can we do David Dickinson
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
Thank you!

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