Skip to content
BOL Conferences
Thread Options
#2261434 - 10/22/21 01:12 PM HELOC Advertisement Intro Rate-How Long?
ItsJustMe Offline
Gold Star
Joined: Dec 2009
Posts: 298
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 テつァ 1026.16, not solely the rules in テつァ 1026.16(d). If an advertisement contains information (such as the payment terms) that triggers the duty under テつァ 1026.16(d) to state the annual percentage rate, the additional disclosures in テつァ 1026.16(b) must be provided in the advertisement. While テつァ 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 テつァ 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 テつァ 1026.60(c) or accompanying applications or solicitations subject to テつァ 1026.60(e).

Return to Top
Lending Compliance
#2261436 - 10/22/21 01:43 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
ItsJustMe Offline
Gold Star
Joined: Dec 2009
Posts: 298
New York
bump... sorry, I'm up against the clock :-)

Return to Top
#2261441 - 10/22/21 02:40 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,529
Bloomington, IN
To the best of my knowledge there is no minimum introductory period under Federal regulations.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2261444 - 10/22/21 02:50 PM Re: HELOC Advertisement Intro Rate-How Long? ItsJustMe
ItsJustMe Offline
Gold Star
Joined: Dec 2009
Posts: 298
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!

Return to Top

Moderator:  Andy_Z