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#21999 - 06/26/02 05:30 PM Truth in Lending on LOC
Anonymous
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When doing a consumer line of credit, is a truth and lending statement needed? On the itemization section what would be listed in a case of the line of credit being $10,000.00 and they draw $1,000.00 on the note date?

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Lending Compliance
#22000 - 06/26/02 05:48 PM Re: Truth in Lending on LOC
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Think "Open End Credit" for this transaction, if it meets the definition. Recurring transactions anticipated? Finance charge imposed from time to time on outstanding balance? Repaid funds again available for draw?

You won't have a "truth in lending" statement as I think you understand that term, nor will you have an itemization of the amount financed. These are both peculiar to closed-end credit.

Instead, you will have an "initial disclosure statement" as described in ยง226.6 of Regulation Z.
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#22001 - 06/26/02 10:25 PM Re: Truth in Lending on LOC
Richard Insley Offline
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Richard Insley
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Posts: 10,232
Toano, VA
In addition to the "initial disclosure statement", there is also the ever-popular "periodic disclosure" which you will have to mail (at inflated postage rates) once per month for the rest of your life. (See Section 226.7.)
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#22002 - 06/27/02 01:09 PM Re: Truth in Lending on LOC
RVFlyboy Offline
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RVFlyboy
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Soaring over Georgia
Of course, you could deliver the disclosures electronically and avoid the inflated postage rates if you jump through all of the E-SIGN and E-Reg hoops.
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#22003 - 06/27/02 01:32 PM Re: Truth in Lending on LOC
Anonymous
Unregistered

Can you do a multiple advance loan up to the maximum but not open end. What would be the disclosure with this.

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#22004 - 06/27/02 03:30 PM Re: Truth in Lending on LOC
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,232
Toano, VA
Sure. It's open-end credit because the available credit is replentished as payments are made--not because multiple advances are possible. You've described the garden-variety construction loan that would be disclosed under Subpart C and your numbers would be estimated in the Appendix D manner.
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