We stopped making HELOCs years ago, but have one maturing next month. The borrower wants a 60 day extension, as he plans to refinance elsewhere.

I've read through posts and 1026.40 and 1026.9, and believe that by having the borrower sign a "Change in Terms/Modification Agreement" prior to maturity, no disclosures or notices are required. I'm hoping it's that simple? Would love confirmation from those more familiar with HELOCs.

If you are not changing any terms and are just extending the maturity - then that would be correct.

Thank you Randy!

What about if a HELOC goes beyond maturity - can we still do an extension (90 days)?

Official Interpretation

Section 1026.40—Requirements for Home-Equity Plans

2. A new plan results, however, if the plan is renewed (with or without changes to the terms) after the scheduled expiration. The new plan is subject to all open-end credit rules, including §§1026.6, 1026.15, and 1026.40.

Thank you!