We have an existing HELOC and borrower is wanting to increase the limit to $75,000. What early disclosures do I need to send in response to this application? It seems most disclosures we normally send when a HELOC is established are not needed on an increase to an existing line. The program disclosure is the same as they did not change the type of HELOC program (but do we send it again), we used an old credit report (within policy guidelines) so no credit score disclosure / notice to home loan applicant (or do we resend?).

I am pulling a new flood determination, we will have ROR, and our bank does a new note when there is an increase in funds rather than do a change in terms.

What about the counselors list? Do we send that again with the acknowledgment of receipt?

I guess we could send everything again and it not be out of compliance....

our bank does a new note when there is an increase in funds rather than do a change in terms.

That implies the new obligation is satisfying and replacing the existing obligation making it a new HELOC plan subject to the 1026.40 disclosures.

we used an old credit report (within policy guidelines) so no credit score disclosure / notice to home loan applicant (or do we resend?).

You need to resend since you used it in this new credit decision. The disclosures advise the consumer about their credit score used in the credit decision and the date of that credit score.

Thank you, Dan. Could we do a Change In Terms then and avoid the re-disclosing? Still have ROR for the new funds and modify the deed of trust for the increased amount.

As long as there are no state prohibitions I know of no reason you could not modify it.

Revisiting - if we do a "new note vs change in terms" but keep the same note number - does that make a difference?

Note numbers do not really mean a thing. That is just an internal thing.