I understand HELOCs are exempt from the successor-in-interest requirements, but I am curious how other institutions are handling the situation where an individual requests to be a successor-in-interest on a closed-end loan secured by a dwelling that also has a open-end HELOC associated with it?

Should we provide information on the HELOC or only provide information on the closed-end loan? When it comes time to payoff, we will want to also collect on the HELOC, so does it make sense to provide information on both loans as soon as the successor-in-interest request is made and the individual confirmed?

Thank you.

Edit: I meant to post this in the Servicing Rules forum. Please feel free to move it. I'm sorry for the confusion.
Last edited by ComplyCycle; 05/10/18 08:44 PM.