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#33009 - 09/17/02 02:52 PM HELOC Initial Disclosure
Tberry Offline
Member
Tberry
Joined: Mar 2002
Posts: 84
Kansas
98% of our HELOCs are a variable rate, discounted Plan A loans. The other 2% are fixed rate, non-discounted Plan B loans. Since the majority of the HELOCs are Plan A can we give the Plan B customers the Plan A initial disclosure or do you need a separate Plan B initial disclosure? Our software company is saying we can use the Plan A disclosure for all HELOCs but I want to be sure. Thanks.

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Lending Compliance
#33010 - 09/17/02 03:36 PM Re: HELOC Initial Disclosure
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
I would say you need both disclosures, I'm basing my answer on 226.5b(d)(6)and (12).

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The opinions expressed are mine and they are not to be taken as legal advice.

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#33011 - 09/17/02 04:48 PM Re: HELOC Initial Disclosure
Tberry Offline
Member
Tberry
Joined: Mar 2002
Posts: 84
Kansas
Thank you for your reply. I also checked with the FDIC and they said I needed two disclosures. I have asked the software company to prepare a disclosure using G-14B as the sample.

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