Posted By: SallyGirl
HELOC with Fixed Rate/Fixed Term Option - 04/12/18 04:08 PM
We are considering offering a HELOC product with a fixed rate, fixed term option where the borrower can convert all or a portion of the outstanding balance on the LOC to a fixed rate/fixed term for a period either 3 years or 5 years. What specific disclosures will be required if and when the borrower chooses to exercise this option?
We looked to 1026.6 to determine the disclosures that would be required but are still not sure of the form of disclosure. Would we give a TIL disclosure and highlight the changes or do we provide a Closing Disclosure for the fixed rate/fixed term portion?
Any thoughts are appreciated.
We looked to 1026.6 to determine the disclosures that would be required but are still not sure of the form of disclosure. Would we give a TIL disclosure and highlight the changes or do we provide a Closing Disclosure for the fixed rate/fixed term portion?
Any thoughts are appreciated.