We print seperate billing notices for our open end HECL lines. If there is no balance required,we do not send a billing statement. What provision in Reg Z allows us to not send this notice if there is no balance owing?

has there been any activity? Check state law, too - some states require periodic statements under certain conditions....

226.7. The creditor shall furnish the consumer with a periodic statement that discloses the following items, to the extent applicable:

If there is no balance, credit or debit activity during the billing cycle a periodic statement is not required under Reg. Z.

I do not see any exemption in Reg. Z based on no activity. Where are you seeing that @Dan? The reference you quoted still leaves room for other things to be disclosed, as it says "to the extent applicable." A HELOC would still have a previous balance, an address for billing errors, and a closing date of billing cycle & ending balance.

1026.5(b)(2)(i): "(i) Statement required. The creditor shall mail or deliver a periodic statement as required by § 1026.7 for each billing cycle at the end of which an account has a debit or credit balance of more than $1 or on which a finance charge has been imposed."

I'm just talking about no activity. So, let's say the balance is $100, but no transactions are made in the billing cycle.

Not sure how that meets this requirement:

1026.5(b)(2)(i): "(i) Statement required. The creditor shall mail or deliver a periodic statement as required by § 1026.7 for each billing cycle at the end of which an account has a debit or credit balance of more than $1 or on which a finance charge has been imposed."

So, you seem to be agreeing with me? I am also stating that I believe it would be required in such a scenario.

Correct - an ending balance of $100 triggers a statement, regardless of whether there are transactions or finance charges imposed.

Thank you for your input. It seems that Dan was potentially saying otherwise above, so just wanted to see if I was missing something.