Our bank was asked to do a 100% participation on a HELOC from an affiliate bank due to Reg O considerations for one of the affiliate's executive officers. It is secured by the principal dwelling. The loan was prepared using our HELOC agreement. Just want to make sure, but did our bank need to provide the right to rescind in this situation? Thank you.

Your bank is the creditor here, since the documents say so and since you will advance the funds. You also issue the rescission notices.

In what respect is this even considered a participation?

John - you're absolutely right, it seems I jumped too quickly. I checked and found out that our bank will not do a "participation" for a HELOC, so we originated the loan and therefore that answers my question. The right to rescind should have been provided. Too much coffee today! Thanks.

Anonymous: Keep in mind that section 215.4 of Reg O applies to extensions of credit to insiders of your affiliates as well as to your own insiders.