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#2051272 - 11/24/15 08:29 PM Heloc at end of the draw period and will now roll
Lilly C Offline
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Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
I am looking for some compliance help for HELOCs that are at the end of the draw period and will now roll to P&I repayments. We have a handful of these type of HELOCs and I want to make sure that we handle them appropriately. (of course, we no longer offer this product)

I have attached a copy of our Credit Agreement for your reference.
1. From everything I have read we should disclose to the borrower well in advance of the rollover reminding the borrower that the loan will be rolling over to the repayment period.
2. What is the requirement for the rollover portion regarding the billing cycle? The interest only portion billed monthly with a periodic statement which dropped the 1st of every month and due by the 21st. Will the new repayment with P&I be due on the 1st with a 15 day grace period since it is now a closed end loan?
3. Is there anything else I am missing….

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#2051313 - 11/24/15 10:15 PM Re: Heloc at end of the draw period and will now roll Lilly C
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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
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#2051456 - 11/25/15 08:55 PM Re: Heloc at end of the draw period and will now roll Lilly C
Lilly C Offline
100 Club
Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
thank you for the prompt response, John. Everyone seems to be out on Holiday!!! I looooooooove you and BankersOnline!!!!!!!!
HappyThanksgiving

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