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#2160902 - 01/18/18 05:43 PM Open-End Credit - Not Home Secured
TeamComply Offline
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In a nutshell, what are the regulatory requirements surrounding open-end credit that is not home secured? This is something the bank is not currently offering, but is considering. Thanks.

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#2160903 - 01/18/18 05:55 PM Re: Open-End Credit - Not Home Secured TeamComply
rlcarey Offline
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Galveston, TX
That is a pretty broad question. Care to narrow it down some. All of Subpart B of Regulation Z will apply, except for those parts that specifically apply to home-equity loans.
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#2160904 - 01/18/18 05:59 PM Re: Open-End Credit - Not Home Secured TeamComply
Richard Insley Offline
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Toano, VA
Will there be a credit card?
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#2160942 - 01/18/18 08:35 PM Re: Open-End Credit - Not Home Secured Richard Insley
TeamComply Offline
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No credit card, just a consumer purpose LOC.

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#2160968 - 01/18/18 10:10 PM Re: Open-End Credit - Not Home Secured rlcarey
Richard Insley Offline
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Richard Insley
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Toano, VA
Originally Posted By rlcarey
All of Subpart B of Regulation Z will apply, except for those parts that specifically apply to home-equity loans
or credit cards. As with any consumer credit, you'll have to comply with Reg. B, privacy, fair credit reporting, and Reg. E's compulsory use prohibition.
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#2162034 - 01/26/18 03:54 PM Re: Open-End Credit - Not Home Secured TeamComply
Obi Offline
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Posts: 181
We have a one year consumer line of credit (revolving). Is this considered open-end and needs to follow Subpart B of Reg Z? Or is it closed end?

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#2162041 - 01/26/18 04:08 PM Re: Open-End Credit - Not Home Secured TeamComply
Skittles Online
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TN
If the borrower can repay the loan and then borrow it back up to the maximum it is a revolving open-end line of credit.
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#2162951 - 02/02/18 05:55 PM Re: Open-End Credit - Not Home Secured TeamComply
MusicCityCRCM Offline
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I'd like to expand on this thread pertaining to open-end credit that does not have a credit card. We are reviewing our periodic statements and are unsure which parts of 1026.7 would apply. When reading 1026.7(b), any information that specifically references credit cards or a card issuer would not be required on a statement for a plan with no card, correct? For example, the minimum payment information that explains to the consumer how long it would take to the pay the account off if they pay the minimum payment only.

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#2163361 - 02/06/18 08:47 PM Re: Open-End Credit - Not Home Secured TeamComply
Gibby Offline
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Joined: Jan 2018
Posts: 13
We are acquiring a bank that has an overdraft line of credit. Transaction fees for each draw are taken from the customer's checking account. Once converted to our system, fees will be charged to the loan and not taken from the customer's deposit account. We believe this is a change of terms that requires 45 day notification. Could someone give me their opinion on this? Thank you!

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#2163603 - 02/08/18 12:14 PM Re: Open-End Credit - Not Home Secured TeamComply
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Without reading your contracts - it is impossible to say.
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