Skip to content
BOL Conferences Top Gun 23
Thread Options Tools
#2630 - 06/28/01 07:00 PM HELOC Fee Disclosures
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
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.

Return to Top
General Discussion
#2631 - 06/28/01 07:30 PM Re: HELOC Fee Disclosures
Lucy Griffin Offline

Diamond Poster
Lucy Griffin
Joined: Nov 2000
Posts: 1,544
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.

Return to Top
#2632 - 09/07/01 12:21 AM Re: HELOC Fee Disclosures

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

Return to Top
#2633 - 09/07/01 01:10 PM Re: HELOC Fee Disclosures
De Vonne Offline
Joined: Jan 2001
Posts: 84
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).]

Return to Top