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#570363 - 06/20/06 07:47 PM HELOC Disclosure
bgehres Offline
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Joined: Mar 2005
Posts: 126
Do we need to give the HELOC disclosure to a non-borrowing owner? My initial thought was that it wasn't required. After reading 226.15(a)(3), I think that it is required to trigger the 3 days from giving the TIL disclosure. This is the first time we've ever had this issue.

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Lending Compliance
#570364 - 06/20/06 08:10 PM Re: HELOC Disclosure
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,761
Bloomington, IN
If you are referring to the plan disclosure, no. But they must receive the payment plan information, such as draw period, repayment period and balloon payment information.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#570365 - 06/21/06 01:14 PM Re: HELOC Disclosure
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
How would you give this information?

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#570366 - 06/21/06 02:10 PM Re: HELOC Disclosure
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,761
Bloomington, IN
It's in our loan agreement.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#570367 - 06/21/06 02:39 PM Re: HELOC Disclosure
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
If one of the owner's is not a borrower, they wouldn't sign the loan agreement. What am I missing?

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#570368 - 06/21/06 02:57 PM Re: HELOC Disclosure
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,761
Bloomington, IN
If they are subject to the ROR they must receive the material disclosures whether they sign the loan agreement or not. How you provide the material disclosures is up to you as long as it is compliant with the Reg.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#570369 - 06/22/06 05:33 PM Re: HELOC Disclosure
bgehres Offline
100 Club
Joined: Mar 2005
Posts: 126
Thanks Dan.

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