Is there any reason why we are not allowed to have First Reserve/LOC statements and HELOC’s to be estatement?
The previous Commentary to Reg Z at 1026.5b contained the following statement regarding a matured HELOC: "...A new plan results; however, if the plan is renewed (with or without changes to the terms) after the scheduled expiration. The new plan is subject to all open-end credit rules, including sections 226.5b, 226.6 and 226.15." I have not found any comparable interpretations by the CFPB since the CFPB took over responsibility for Regulation Z. I'm looking for any information that will support the need, or lack thereof, to require a Notice of Right to Cancel when a new HELOC note is executed after the existing HELOC has matured.
Is a loan to purchase a shed, HMDA reportable as home improvement? Does the shed have to be on a permanent foundation to qualify as a home improvement?
On a unsecured note, what address has to be on there. Can it be the mailing address which is a PO Box or does it have to be the borrowers physical address?
We are looking to increase our late fees on our consumer loans (installment and line of credit) not affecting any HELOC or mortgages at the first of the year. I know based on our current disclosures we cannot increase late fees on existing loans but can on the new loans made going forward. I am looking to see if we need to provide our membership with a notice of increase in fees? If so, does it need to be in a newsletter or can it be a hard coded message on the statements? I can't seem to locate this within Reg Z rules.