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#63133 - 02/24/03 04:00 PM HELOC's - DDA stmt ?
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Our HELOC's are accessed by checks. These checks go thru a DDA account (sweep)issued in the customers name. Each month the DDA account should have a "0" balance. Is it necessary to send these DDA accounts to customers. We send monthly HELOC stmt that basically shows all the transactions that "sweep" thru DDA accounts.
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General Discussion
#63134 - 02/24/03 04:55 PM Re: HELOC's - DDA stmt ?
JMB Offline
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JMB
Joined: Mar 2002
Posts: 59
Michigan
Reg Z 226.8 indicates that you probably need to provide the DDA statements, otherwise, you will not see the individual transactions as required.

226.8 states:
Identification of Transactions (01/01/93)

The creditor shall identify credit transactions on or with the first periodic statement that reflects the transaction by furnishing the following information, as applicable.16

--------------------------

16 Failure to disclose the information required by this section shall not be deemed a failure to comply with the regulation if:

(1) The creditor maintains procedures reasonably adapted to obtain and provide the information; and

(2) the creditor treats an inquiry for clarification or documentation as a notice of a billing error, including correcting the account in accordance with 226.13(e). This applies to transactions that take place outside a state, as defined in 226.2(a), whether or not the creditor maintains procedures reasonably adapted to obtain the required information."



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#63135 - 02/24/03 05:54 PM Re: HELOC's - DDA stmt ?
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,353
Galveston, TX
I don't think so. We use to process the same way. You are just using the DDA processing system and a "shadow" DDA account (I am assuming). As long as you are passing the check number to the HELOC statement - you should be fine.
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#63136 - 02/24/03 06:43 PM Re: HELOC's - DDA stmt ?
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Thanks - That's exactly what we do.
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#63137 - 02/24/03 07:19 PM Re: HELOC's - DDA stmt ?
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
I only thought that's what we do. Come to find out, the check number is not on the HELOC stmt.
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#63138 - 02/24/03 07:37 PM Re: HELOC's - DDA stmt ?
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Found out ck number is not reflected on HELOC stmt. Is that a problem?
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#63139 - 02/24/03 08:00 PM Re: HELOC's - DDA stmt ?
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
What does it show in the description?
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#63140 - 02/24/03 08:12 PM Re: HELOC's - DDA stmt ?
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
the date - the $ amount - the description is "advance"
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