Forebearance

HELOC matured and we are trying to work with customer on repayment. Will likely be entering into a forebearnce agreement which will just be a fixed payment over several years at a lower interest rate. So payment is higher because it was interest only before, but overall the interest rate is lower.

Do we have to redisclose anything to this customer when using a forebearance agreement to workout of a matured open-end credit. If this was closed end credit .20 would tell me I'm okay, but since its open-end credit there is not as good of guidance.

17(b) Time of Disclosures

2. Converting open-end to closed-end credit. Except for home equity plans subject to §1026.40 in which the agreement provides for a repayment phase, if an open-end credit account is converted to a closed-end transaction under a written agreement with the consumer, the creditor must provide a set of closed-end credit disclosures before consummation of the closed-end transaction.

You are correct. 1026.20 will not apply to open-end credit and there is no similar exception.