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#1629933 - 11/17/11 08:59 PM HELOC tied to Existing Checking Account
Still Smiling Offline
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Joined: Nov 2007
Posts: 767
Can anyone tell me if there are any concerns I should have over linking an existing checking account to an existing HELOC?
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Comments are strictly my own and not that of my employer.

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Lending Compliance
#1629959 - 11/17/11 09:25 PM Re: HELOC tied to Existing Checking Account Still Smiling
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
If State law allows it, you would just have to provide the proper disclosures to add an additional access device under 226.9(b). It would be illegal in Texas.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1629983 - 11/17/11 09:42 PM Re: HELOC tied to Existing Checking Account rlcarey
Still Smiling Offline
Platinum Poster
Joined: Nov 2007
Posts: 767
Thanks for responding. What does the disclosure need to say? Our application disclosure for the HELOC states that acessibility can be by HE check, phone request, by mail, in person, debit card, etc.
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Comments are strictly my own and not that of my employer.

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#1630006 - 11/17/11 10:14 PM Re: HELOC tied to Existing Checking Account Still Smiling
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
The regulation tells you in the section I cited.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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