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#2244693 - 10/27/20 05:08 PM HELOC Historical Index Table Example Error
WDCA Offline
Member
Joined: Nov 2015
Posts: 85
We overlooked the historical index update requirement that we normally do in January. Our HELOCs from February to September didn't receive the most current index example.

Is anyone aware if there is guidance to point to that says whether or not we should re-send the updated disclosures to all affected during this time frame? Thanks in advance for any suggestions!

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Lending Compliance
#2244699 - 10/27/20 05:32 PM Re: HELOC Historical Index Table Example Error WDCA
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The historical table example is a requirement for the Plan Disclosure required to be given at application. Sending an update now would IMO serve no purpose.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2244713 - 10/27/20 08:46 PM Re: HELOC Historical Index Table Example Error WDCA
WDCA Offline
Member
Joined: Nov 2015
Posts: 85
Thank you

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