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#467971 - 12/08/05 07:55 PM Another odd Home Equity Line of Credit Question
poppy Offline
100 Club
Joined: Nov 2005
Posts: 224
Let's say the bank wants to change their current home equity line of credit product from a fee (paid by the borrower) to a non-fee p.o.c. (paid by the bank) product. Is the bank violating Reg. Z if they don't change their disclosures and loan documents to reflect the fact the borrower doesn't pay any fees? The only place the p.o.c. would be reflected is on the Note and HUD-1A.

Any help is appreciated.

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Lending Compliance
#467972 - 12/08/05 08:00 PM Re: Another odd Home Equity Line of Credit Question
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
Not IMO.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#467973 - 12/08/05 08:17 PM Re: Another odd Home Equity Line of Credit Question
poppy Offline
100 Club
Joined: Nov 2005
Posts: 224
Dan, why do you think the bank wouldn't be in violation of Reg. Z?

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#467974 - 12/08/05 08:48 PM Re: Another odd Home Equity Line of Credit Question
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
They are still fees associated with the account, they are just being POC by the lender.

226.5b(d) (and the OSC)

(7) Fees imposed by creditor. An itemization of any fees imposed by the creditor to open, use, or maintain the plan, stated as a dollar amount or percentage, and when such fees are payable.

(8) Fees imposed by third parties to open a plan. A good faith estimate, stated as a single dollar amount or range, of any fees that may be imposed by persons other than the creditor to open the plan, as well as a statement that the consumer may receive, upon request, a good faith itemization of such fees. In lieu of the statement, the itemization of such fees may be provided.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#467975 - 12/08/05 08:52 PM Re: Another odd Home Equity Line of Credit Question
poppy Offline
100 Club
Joined: Nov 2005
Posts: 224
Thanks, Dan.

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