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#969743 - 06/05/08 01:39 PM Reg Z - HELOC program disclosure
AuditorK Offline
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Joined: Feb 2003
Posts: 961
PA
I'm just getting my feet wet in lending compliance and I have the following question. Does there need to be a copy of the "initial program disclosure" placed in the loan file to document compliance? If so, should it be signed by the borrowers? I'm assuming we just hand out the "When your home is on the line..." brochure at application and won't have way to prove compliance with that requirement.

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Lending Compliance
#969758 - 06/05/08 01:49 PM Re: Reg Z - HELOC program disclosure AuditorK
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,464
Bloomington, IN
There is no regulatory requirement to have a copy of the plan disclosure in the file nor have it signed by the applicants.

You have to document your process in how you provide the disclosures and demonstrate that process works.

We use application packets that have all the required disclosures for the specific product.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#969780 - 06/05/08 02:10 PM Re: Reg Z - HELOC program disclosure AuditorK
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 961
PA
Thanks for the quick response Dan!

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#969802 - 06/05/08 02:26 PM Re: Reg Z - HELOC program disclosure AuditorK
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
Dan's advice is very good. You reduce risk by strengthening systems in favor of getting signatures on everything.
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