Skip to content
BOL Conferences
Thread Options
#2268502 - 03/31/22 04:34 PM HELOC Periodic Statement Requirements
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Our IA is planning to cite a violation of 1026.7(a) as our HELCO statement does not have the Bank's name and address in the upper left corner like our mortgage statements do.

I reviewed 1026.7(a) 1-10 and I only see that (9) requires an address for billing errors. We include the Bank's address in the Reg Z Billing Error Notice on the backside of the statement. On the front, the Bank's address is in the tear off coupon to be used to mail the payment.

We are a Fiserv bank. I have no idea if the statement is set up correctly. Maybe there is a feature that enables us to put the Bank's contact information in the upper left corner like our mortgage statements. That is being researched.

Regardless, I don't feel that we have a violation. Any thoughts on this?
_________________________
TryingToComply
CRCM

Return to Top
Lending Compliance
#2268505 - 03/31/22 04:52 PM Re: HELOC Periodic Statement Requirements TryingtoComply
Inherent_Risk Offline
Platinum Poster
Joined: Jan 2017
Posts: 573
I do not think you have a violation. Model forms don't even have it in the upper left.

Return to Top
#2268519 - 03/31/22 06:26 PM Re: HELOC Periodic Statement Requirements TryingtoComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,358
Galveston, TX
Agree - ask them what citation in 7(a) they are referring too?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2268540 - 03/31/22 09:17 PM Re: HELOC Periodic Statement Requirements TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Ha! smile He said 7(a)(9). So we are good.
_________________________
TryingToComply
CRCM

Return to Top

Moderator:  Andy_Z