HELOCs for Purchase - 07/12/01 02:04 AM
[This message has been edited by Angela (edited 07-12-2001).]
[This message has been edited by Angela (edited 07-12-2001).]
Also, our loan processing area is concerned because they are getting requests to do HELOCs with multiple collateral (i.e. the dwelling and stock/car/etc.) Our product does not provide for adding additional collateral, but I wanted to make this was even permitted? Thank you.
As for multiple collateral, I suppose you can fashion a loan in a variety of ways. BUT -- there is the IRS to consider. If the security is something other than the borrower's home, the tax deduction angle is going to be lost. And if more and more lenders do this, IRS may take steps to limite the deductability of HELOC interest. They're itching to do this anyway.
But I still stink you have to provide the rescission notice. After the borrower makes their first payment on the account, the line may have available credit. The borrower can draw that amount any time.
I think that situation is the reason the Regulation reads the way it does.
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Opinions expressed are not necessarily those of my employer.
Paul Brinker CRCM
Director, Corporate Compliance
First National Bank of Omaha
402-964-8313
Doesn't mean I'm going to do it, or am even able to do it, but I AM contemplating.....
In my transaction, the lender was going to sell the home equity line (don't ever tell HUD that this can be done!) and was dotting all i's and crossing all t's. They asked me to write out the waiver explaining my personal financial emergency so the loan would have everything the purchaser was looking for.
So, being a good compliance geek, I sat down and wrote, in my own handwriting, that I was waiving my right to rescind because I didn't have the right to rescind because this was a purchase money loan. Every now and then I wonder if anyone read that and, if so, what they think!