beegee
Diamond Poster
Joined: Feb 2004
Posts: 1,110
South
We are wanting to start a new personal loan product: an open ended variable rate loan secured by a CD. What disclosures are entailed? Is is similar to a HECL?
Cowboys Fan
Power Poster
Joined: Dec 2002
Posts: 4,619
SC
The definition of open-ended credit in Reg Z isn't limited to real estate secured lines. If you go to Subpart B it will walk you through the required disclosures, including the periodic statements.