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#2180310 - 05/31/18 04:39 PM Question around HELOC statements and SIIs
GTS333 Offline
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Joined: Jun 2010
Posts: 257
I know the new TILA/Reg. Z requirements tell me I need to treat confirmed successors in interest as consumers for purposes of sending them a periodic statement for closed-end mortgage loans (12 CFR 1026.41). Does anyone know why the CFPB didn't similarly require us to send periodic statements to confirmed successors in interest for HELOCs? Unless I'm just missing it in all the back and four thing of the new definitions, but I don't see that requirement anywhere.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

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Mortgage Servicing Rules
#2180342 - 05/31/18 05:55 PM Re: Question around HELOC statements and SIIs GTS333
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 570
HELOCs just weren't within the scope of the rule changes.

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#2180361 - 05/31/18 06:59 PM Re: Question around HELOC statements and SIIs GTS333
GTS333 Offline
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Joined: Jun 2010
Posts: 257
Thanks, Inherent_Risk. I agree with you, I'm just a little stumped on why not. That said, less work I suppose.

Thanks
_________________________
My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

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