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#2172893 - 04/10/18 09:27 PM Including Bankruptcy Notice on HELOC Stmt
kglasser Offline
Member
Joined: Jun 2016
Posts: 67
Is there anything that would prohibit including the same 7/11 or 12/13 bankruptcy notices the Rules require on closed-ended HE Loans on HELOC statements? Collections would like to incorporate the same processes and notices for both product types (open and closed end dwelling secured).
Thoughts?

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Mortgage Servicing Rules
#2172986 - 04/11/18 03:58 PM Re: Including Bankruptcy Notice on HELOC Stmt kglasser
GTS333 Offline
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Joined: Jun 2010
Posts: 257
I'm not sure specifically which "notices" you're referring to, but you'd be building your own version of the periodic statements for open-end loans, and it would still have to comply with all of the requirements and restrictions for open-end statements under Reg. Z. I'm not sure that's doable, but I haven't tried to marry the two requirements. I'd personally continue to not provide statements to consumers in BK on open-end loans rather than try to create my own compliant statement version, as I suspect that's far less risky, but that's just me. Good luck!
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