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#2198421 - 11/16/18 01:27 PM HELOC-Default-charging fees previously absorbed
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
We don't charge the 3rd party fees for a HELOC - basically we pay those charges ourselves. We do disclose in the application disclosure and the agreement that in the event it is closed out within the first three years after origination, that these third party fees will be charged as an early termination fee (not a prepayment penalty under 1026.32). Can we also charge the customer these third party fees if the loan goes in to default as long as we disclose such?

Thanks in advance.
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Lending Compliance
#2198426 - 11/16/18 02:19 PM Re: HELOC-Default-charging fees previously absorbed Likes to Comply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
That would be a state law issue but IMHO it most likely will violate your state's late charge limitations.
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#2198441 - 11/16/18 03:21 PM Re: HELOC-Default-charging fees previously absorbed Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
Thanks...I'll look that up.
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