If a customer obtains a LARGE line of credit for personal use but the bank takes the customer's home as an "abundance of caution", are the disclosure requirements to follow 12 CFR 226.5(a)-Credit Cards or should the bank handle it like a Home Equity under 12 CFR 226.5(b)?

I'm wondering if a Laser Pro Revolving Credit Agreement and Disclosure satisfies adequately the requirements. There were FINANCE CHARGES assessed at inception and they are broken out and disclosed on the agreement as "Additional Finance Charges" but the APR disclosed is the interest rate given and there is a separate section that breaks out a "Daily periodic rate" to be disclosed on periodic statements.

Help! I think I really need to call it a day, I think I'm over thinking this.
Any guidance would really help!

From what I understand, the fact that you're taking the property as an "abundance of caution" is irrelevant when it comes to RESPA and Reg Z. If you take their primary residence as collateral for an open-end consumer purpose loan, for all intents and purposes, you have a HELOC and the appropriate HELOC disclosures should be given.

KQuinn is absolutely correct. The only thing ABC relieves you of is some appraisal requirements. You have to follow all the disclosure requirements of 226.5b. And don't forget the flood requirements.