Could someone help me confirm whether there is a requirement under Reg Z to provide a good faith estimate and/or settlement statement? Our open-end plan disclosures include a statement that if a borrower has to pay third party fees we will provide them an itemization upon their request, which appears to be consistent with what we read in Reg Z.

Under Regulation Z there is no such thing as a Good Faith Estimate. Z requires early disclosures, which in the case of HELOCs are so detailed that they not only meet the Z disclosure requirements, they replace the RESPA requirements.

HUD has exempted HELOCs from the GFE and the HUD-1 because that information is covered in the Reg Z disclosures. So the HELOC disclosures become the equivalent of and substitute for GFEs and HUD-1s.

See 226.5b(d)8 Manner of describing fees. A GOOD FAITH ESTIMATE of the amount of fees must be provided..............

I was doing a little research myself and ran across this. When we hear the words good faith estimate we automatically think of RESPA, but they do appear in Reg Z too.

Dolly Nugent
VP/Compliance Officer
Citizens Business Bank

Lucy and Dolly are both correct. However, Angela seems to be asking if you need to provide the GFE/Settlement Statement forms that are required by RESPA. The answer is no. Section 226.5b(d)(8) requires an estimate stated as a single dollar amount or a range of fees or an itemization, but not to the extent of the RESPA-GFE in terms of payee names, required providers, etc.

[This message has been edited by De Vonne (edited 09-07-2001).]