Posted By: Tryin-2-Comply
HELOCs tied to a DDA as an ODP - 02/26/11 01:21 AM
We have very few DDA accounts where we have allowed them to tie their HELOC to it as an ODP - so the customer would have access to their HELOC funds in the event their DDA became overdrawn.
I am "thinking" that this was done without any compliance consideration many years ago. So, I am trying to backtrack to figure out what we need to do with these few accounts. I don't think credit card rules apply since this is not direct access with a card. Are there other things we need to ensure we are covered on? DDA disclosures, HELOC disclosures, etc. Does anyone allow this?
Many thanks.
I am "thinking" that this was done without any compliance consideration many years ago. So, I am trying to backtrack to figure out what we need to do with these few accounts. I don't think credit card rules apply since this is not direct access with a card. Are there other things we need to ensure we are covered on? DDA disclosures, HELOC disclosures, etc. Does anyone allow this?
Many thanks.