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#2261434 - 10/22/21 01:12 PM HELOC Advertisement Intro Rate-How Long?
ItsJustMe Offline
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Joined: Dec 2009
Posts: 285
New York
I'm confused. How long does a HELOC introductory rate have to be in effect? Is it 6 months like other open-end products?

Section 1026.16(d)-7 states:
Relation to other sections. Advertisements for home-equity plans must comply with ALL provisions in § 1026.16, not solely the rules in § 1026.16(d). If an advertisement contains information (such as the payment terms) that triggers the duty under § 1026.16(d) to state the annual percentage rate, the additional disclosures in § 1026.16(b) must be provided in the advertisement. While § 1026.16(d) does not require a statement of fees to use or maintain the plan (such as membership fees and transaction charges), such fees must be disclosed under § 1026.16(b)(1)(i) and (b)(1)(iii).
BUT...
1026.16(g) states:
The requirements of this paragraph apply to any advertisement of an open-end (not home-secured) plan, including promotional materials accompanying applications or solicitations subject to § 1026.60(c) or accompanying applications or solicitations subject to § 1026.60(e).

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#2261436 - 10/22/21 01:43 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
ItsJustMe Offline
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Joined: Dec 2009
Posts: 285
New York
bump... sorry, I'm up against the clock :-)

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#2261441 - 10/22/21 02:40 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,631
Bloomington, IN
To the best of my knowledge there is no minimum introductory period under Federal regulations.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2261444 - 10/22/21 02:50 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
ItsJustMe Offline
Gold Star
Joined: Dec 2009
Posts: 285
New York
Thank you so much Dan! I hate to say it, but I've been interpreting that requirement incorrectly for a long time. Glad you set me straight!

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