Home Equity LOC-Denials

Posted By: DCollins

Home Equity LOC-Denials - 05/21/02 08:12 PM

We started an application for a Home Equity Line of Credit and two weeks later we realized that the value of the collateral was not sufficient. We are turning down the loan and we need to know what disclosures we are required to give to the customer along with the adverse action notice? Or, should we consider that this application was not complete until we received the appraisal information and none of the early disclosure apply?
Posted By: Lucy Griffin

Re: Home Equity LOC-Denials - 05/21/02 10:48 PM

The disclosures that you give the customer for a HELOC application were due with the application form. See 226.5b(b). Since you are planning a denial, you are left with only the adverse action notice and the notice of a right to a copy of the appraisal.