CD open-end

Posted By: beegee

CD open-end - 04/22/05 04:08 PM

We are wanting to start a new personal loan product: an open ended variable rate loan secured by a CD. What disclosures are entailed? Is is similar to a HECL?
Posted By: Cowboys Fan

Re: CD open-end - 04/22/05 05:47 PM

The definition of open-ended credit in Reg Z isn't limited to real estate secured lines. If you go to Subpart B it will walk you through the required disclosures, including the periodic statements.