I recently had a couple HELOC's come across my desk where I am second guessing which loan term to report.
Below are similar dates from my scenario:
Origination Date: 8/10/2022
Maturity Date: 8/09/2022
Draw Period: 120 Months
Comment 4(a)(25)-4 states
For an open-end line of credit with a definite term, a financial institution reports the number of months from origination until the account termination date, including both the draw and repayment period.
Since the time from origination to maturity is technically not a full 120 months, but the draw period is stated as 120. Should term be reported as 120 months to include the draw period or 119 to show origination to maturity?