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#501688 - 02/21/06 09:19 PM HELOC advertising
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
We are going to offer a 15 year product that will be billed interest only for 60 months. The interest will be billed monthly. There will be no minimum payment required. After the 60 months, the line would go back to the normal terms and the payment would be calculated and billed.

The question I have is: do we have to make any special disclosures because this is an interest only loan for the first 60 months? I can't find anything in Reg. Z that would lead me to think that I would need to do this.
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Marketing
#501689 - 02/21/06 10:12 PM Re: HELOC advertising
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
"There will be no minimum payment required."

If this loan can negative amortize - that would have to be disclosed.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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