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#2247253 - 01/06/21 03:30 PM HELOC Early Termination Fee
Luv2run Offline
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Joined: Jan 2015
Posts: 610
We are in the process of putting together a new HELOC product that will include an early termination fee. I have no experience with this type of fee and was wondering if it needed to be included on the initial program disclosure and/or Note. I have read it is not considered a finance charge so I am not really sure where to go with it.
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#2247254 - 01/06/21 03:39 PM Re: HELOC Early Termination Fee Luv2run
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
See the commentary to Paragraph 40(d)(4)(i) for the early disclosure.

If you don't have it in your HELOC note/agreement however, I am at a loss as to how you would impose it on a consumer.
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#2247255 - 01/06/21 03:45 PM Re: HELOC Early Termination Fee Luv2run
Luv2run Offline
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Joined: Jan 2015
Posts: 610
Thanks very much! I figured it had be disclosed somewhere so the borrower is informed, I just didn't know where to look. You have set me in the right direction.
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