We are considering offering a HELOC product with a fixed rate, fixed term option where the borrower can convert all or a portion of the outstanding balance on the LOC to a fixed rate/fixed term for a period either 3 years or 5 years. What specific disclosures will be required if and when the borrower chooses to exercise this option?

We looked to 1026.6 to determine the disclosures that would be required but are still not sure of the form of disclosure. Would we give a TIL disclosure and highlight the changes or do we provide a Closing Disclosure for the fixed rate/fixed term portion?

Any thoughts are appreciated.

Closing Disclosure - no - it is part of the open-end credit, unless paying the amount down does not increase the available credit in the HELOC. What you have to give them at the time will depend on what you include in your initial disclosures.

My bank has also been discussing the idea of allowing our HELOCs to have features similar to those described by SallyGirl. If anyone has an example of the disclosures & note they use, it would be appreciated.

There are a number out on the web.