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#2276387 - 10/05/22 02:20 PM Business Purpose HELOC
terpsfan Offline
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Joined: Feb 2007
Posts: 2,119
If a customer indicates that they will be using their HELOC for business purposes would there be any issues with still originating, it as a consumer HELOC?

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#2276388 - 10/05/22 02:26 PM Re: Business Purpose HELOC terpsfan
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,883
Bloomington, IN
This is a pet peeve of mine.

1. Why would you price a business purpose RLOC as a consumer HELOC?
2. Why would you use a consumer HELOC legal agreement that restricts your ability to freeze or terminate the LOC? You are giving the borrower regulatory protections they are not entitled to under the regulations.

Outside of that there is no regulatory restrictions for processing it through your consumer HELOC program that I am aware of.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2277445 - 11/01/22 09:15 PM Re: Business Purpose HELOC terpsfan
TryingtoComply Offline
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Joined: Apr 2013
Posts: 2,323
The West
At most banks that I have worked for the program parameters clearly indicated that the product was to only be used for consumer purposes for the reasons cited by Dan.
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TryingToComply
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