No. 7(a)(6)(ii) Other Charges - Covers charges actually assessed to the HELOC. Closing costs not charged to the HELOC are only disclosed on the account disclosure delivered under 1026.6(a). If you are choosing to use a periodic statement designed for credit cards under .7(b), which is optional for HELOCs, unless they are assessed to the plan itself, I do not believe you would be required to include them on the statement.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com