Billing-Error Rights & HELOCs Accessed By A Card

Posted By: Compliance Poster

Billing-Error Rights & HELOCs Accessed By A Card - 02/16/21 07:09 PM

We are adding the use of a Card to access HELOCS. As such, do we need to add the Special Rule for Credit Card Purchases text at the end of the billing rights statement for HELOCs (G–3—Long-Form Billing-Error Rights Model Form (Home-Equity Plans)? I appreciate your guidance.
Posted By: rlcarey

Re: Billing-Error Rights & HELOCs Accessed By A Card - 02/18/21 11:26 PM

Yes. Read the commentary in Appendix G.

1026.6(a)(5) Statement of billing rights. A statement that outlines the consumer's rights and the creditor's responsibilities under §§1026.12(c) and 1026.13 and that is substantially similar to the statement found in Model Form G–3 or, at the creditor's option, G–3(A), in Appendix G to this part.

Official Interpretation
6(a)(5) Statement of Billing Rights
1. See the commentary to Model Forms G–3, G–3(A), G–4, and G–4(A).