We are changing our repayment of HELOCs to an amortization (with new accounts and customers who agree to modify). We will no longer have HE statements because we are doing away with Equicheck. Because of this, Jack Henry has created a billing statement that will go out. On the billing statement, it states the APR. Should the APR be stated on the billing statement? I am thinking yes, but a loan processor questioned it so I wanted to make sure.

Also, what is the time frame we will need to send this to the customer?

Thanks!

Are you converting these to closed end credit or are you just changing your required payment to one that assumes an amortization over a period of time?

Not really sure what you are doing since you reference "new accounts" will be amortized.



If these are remaining as open-end accounts then you cannot do away your periodic statements and they must continue to follow the requirements of 226.7.

We will start to issue billing statements with our new product - interest pymt only helocs.
We have never sent billing statements before for a loan product.
I have found all the information that needs to go on the back of the billing - error resolution, etc.
But what section tells me what needs to be included on the front?

Is it the same as what is required to be listed on the periodic statement (which we will still provide as a combined checking / savings / loan statement)?

I would read 1026.7 (periodic statement)should tell you what you need

Thank you. I thought that was the correct section but I was getting confused on whether there was a difference between periodic statement and billing statements.

Is the G-18(G) Periodic Statement format the correct format that is acceptable if we go with section (b) of 1026.7? Does it require the minimum payment warning and payment example if this is a HELOC and not a credit card?