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#2222879 - 10/02/19 06:28 PM REG Z Identification of nonsale credits
Compliance Advisor007 Offline
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Joined: Oct 2019
Posts: 2
If a member writes a check drawn from a HELOC account, does the transaction description "advance" suffice? Or does the description on the statement need to reflect that there is a check associated with the advance?

thanks!

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#2222903 - 10/02/19 08:22 PM Re: REG Z Identification of nonsale credits Compliance Advisor007
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod

Regulation Z, §1026.8(b):

(b) Nonsale credit. For each credit transaction not involving the sale of property or services, the creditor must disclose a brief identification of the transaction; the amount of the transaction; and at least one of the following dates: The date of the transaction, the date the transaction was debited to the consumer's account, or, if the consumer signed the credit document, the date appearing on the document. If an actual copy of the receipt or other credit document is provided and that copy shows the amount and at least one of the specified dates, the brief identification may be omitted.

Also note comment 8(b)-4:

4. Nonsale transaction—sufficiency of identification. The creditor sufficiently identifies a nonsale transaction by describing the type of advance it represents, such as cash advance, loan, overdraft loan, or any readily understandable trade name for the credit program.

Anything additional in the description is optional.

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John S. Burnett
BankersOnline.com
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