It is not a closed end loan. It continues to be open-end credit in spite of the fact that the borrower can no longer draw funds and repayment has begun. So you continue to bill it on your open end system using the same cycle and due dates as before, but you have a new minimum payment amount calculated to amortize the loan according to whatever you disclosed back when the account was opened. There are no disclosures to be made. It's a good idea, though, to remind the borrower of the end of the draw period and the start of the repayment period.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8