Forgive my ignorance, but the bank I work at does not offer any consumer loan products that are secured by Real Estate. The Bank does have a few HELOC loans in the portfolio that funded close to 10 years ago. Per the HELOC plan the loans are going to start terming out at the 10 year mark. They convert to a repay period of 10 years. Is there any part of RESPA that would apply to the Bank? Mainly wondering if there are any servicing type requirements that could apply to the HELOCS either prior to or after they convert to the repay period? The way I read the regulation nothing in RESPA would apply but I am not totally up to speed on all things TRID as we have not had to deal with it, and that seems to muddy the waters for me.

The fact that the HELOC has reached the repayment period does not impact the fact that they remain governed under the open-rules and the original HELOC contract. You will continue to provide them period statements as you have when the line was in the draw period. The fact that it has reached the repayment period does not make this a closed-end loan subject to any of the closed-end Reg. Z or RESPA rules.

Thank you! I assumed as much but it is always good to get some confirmation.