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#7417 - 12/05/01 05:05 AM LOC Non-Usage Fees
cervesa Offline
Member
cervesa
Joined: Jun 2001
Posts: 56
Santa Fe, NM
We are considering adding a non-usage fee to our lines of credit. It has not been decided whether to apply a flat fee or a fee based on the percentage of the unused portion of the line. What are my regulatory issues?

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General Discussion
#7418 - 12/04/01 06:02 PM Re: LOC Non-Usage Fees
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Are these consumer or business purpose? If consumer, are they equity lines or unsecured?

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#7419 - 12/04/01 06:05 PM Re: LOC Non-Usage Fees
cervesa Offline
Member
cervesa
Joined: Jun 2001
Posts: 56
Santa Fe, NM
They are consumer equity lines. Thanks.

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#7420 - 12/04/01 08:59 PM Re: LOC Non-Usage Fees
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Only changes that unilaterally benefit the customer or are insiginficant or to which the customer agrees in writing can be made on HELOCs originated since ~11/89. See 226.5b(f).

Adding a fee would not fit the requirements.

------------------
Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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