If an applicant applies for a HELOC and the margin is 1 over, the during the application process the margin is increased to 1.5 over. Do you not have to give the customer a new program disclosure with all the information as this would be considered a new product? or honor the opriginal? I am going round and round on this one.
Thanks

Margins are negotiable and a change in the margin does not constitute a new Plan. That is why there is a statement in the Plan disclosure informing the applicant they should inquire about the lender's current margin.

thanks

But they would not be able to change the margin once the loan closes.

Once the HELOC is consummated you cannot adversely change the terms of the contract unless the borrower expressively agrees to it in writing.