Texas has a 12 day waiting period on all home equity loans, which prohibits the lender from closing the loan before the 12 day "cooling off" period. This raises a question when the applicant changes from a closed end home equity to a home equity line of credit, do you have to start the clock over again? I want to post beyond the Texas forum to ask, when this happens outside of Texas, are you in compliance with federal regulation if you give the Fed brochure and product disclosure at the time the applicant switches from the closed end to the line of credit? Is that considered provided at the time of application, or do you have to close out that application and start a new one for the line, providing disclosures at the new appl date, in order to be compliant?

If a person applies for a closed-end home eq ln and decides later to change the application to a HELOC, you would give the HELOC upfront disclosures at that time. Whether you make him complete a new application form or not depends on your bank's policy. We would not. We would notate on the original app form that the customer changed products, noting the date we were informed of the change.