Two questions:

1. Does a bank need to redisclose on a HELOC if the loan amount changes? Our quandry here is that the interest rate and fees do not change even if the loan amount does.

2. Does a bank need to send redisclosures on a HELOC for counteroffers (say if the LTV comes back lower than expected). Again, the interest rate and fees would not change.

We appreciate the discussion.

An early HELOC disclosure is a program disclosure and is not loan specific, unless you have chosen to make it so.

Thank you Randy. That's what I thought, but Consumer Lending was concerned, so I reached out to this trusted site for confirmation.