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#2194567 - 10/03/18 04:16 PM HELOC Rate Spread/Reg Z
whitney0089 Offline
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Joined: Jul 2018
Posts: 13
I'm reading the guide and have myself confused.

Rate Spread is not applicable to loans that are NOT subject to Reg Z.

I'm "thinking" HELOC's are not subject to Reg Z but I can't seem to find that in any of the new 2018 updated information. Is this still the case?

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#2194570 - 10/03/18 04:21 PM Re: HELOC Rate Spread/Reg Z whitney0089
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,628
Galveston, TX
For open-end lines of credit, a financial institution complies with ยง1003.4(a)(12)(i) by relying on the annual percentage rate for the covered loan, as calculated and disclosed pursuant to Regulation Z, 12 CFR 1026.6.
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#2194578 - 10/03/18 05:13 PM Re: HELOC Rate Spread/Reg Z whitney0089
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
HELOC's can certainly be for consumer purposes and, if so, are subject to Reg Z. Lots of banks do this. Maybe your institution doesn't make open-end loans or HELOCs to consumers.

If you do offer HELOC's to consumers, follow Randy's post.
If you don't offer HELOC's to consumers, all of your open-end credit would be reported as NA for Rate Spread.
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