Posted By: Retired DQ
HELOCS & Check 21 - 03/25/04 08:58 PM
Our IT guy said that we have to update our HELOC agreement to include a disclosure about Check 21, is anyone else doing this?
Thanks...
Thanks...
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Couldn't these disclosures be combined with the Reg E we already provide with our HELOCs?
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Maria,
There's a rule that says every day you should do something that scares you, so I am responding...
If your HELOC is accessible by check, it is possible that one of those checks may be presented to you for payment as a substitute check. However, Check 21's "dislcosure" is only triggered when the consumer might receive a substitute check - do you send original checks back to the borrower?
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under what conditions is a transaction on a HELOC subject to Regulation E?
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My reading of Check 21 only defines a "deposit account" as an account subject to the rule. I don't believe a credit account, such as a HELOC would be subject to Check 21 rules.
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My reading of Check 21 only defines a "deposit account" as an account subject to the rule. I don't believe a credit account, such as a HELOC would be subject to Check 21 rules.
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We give Reg E disclosures because we allow access by ATM/Debit card and also telephone transfers.