Do Home Equity Disclosures have to be updated with the change in the index rate or do you just do one annually?
We are a credit union and want to make sure that I'm reading this right concerning HELOCs. Under the rule financial institutions originating 100 or more HELOCs will file 2020 HELOC data, but if we originate fewer than 500 in 2018 or 2019 we would not be required to begin collecting and reporting HELOC data until January, 1 2020.
As a credit union do we fall under this rule as well?
We are going to offer Partition HELOC loans (a main HELOC and fixed rate partitions). How are these reported to the credit bureau? Just the main HELOC and the fixed rate partitions or just the main HELOC?
Does TRID apply to HELOC's? Do I need to have LE's out within 3 days of an application?
If a borrower finances their closing costs on a HELOC, we provide an itemized billing statement. Our software then requires that 100% of those financed fees be paid in full with the first billing on top of any other P&I payment required. Are the financed fees required by the regulations to be paid or is this a software billing issue?
On an Adverse Action notice, how should the term of a HELOC be reported? Our HELOCS are 120/180: A 120 month draw period and a 180 month payback period. Should the term of the loan be displayed as 300 months?
My institution is launching a new product in the upcoming months, HELOC's. We are currently building the policy and disclosures. It was asked of me if we were required to provide a grace period on payments for the HELOC. I was researching but could not find anything particular.
Currently, our HELOC products feature a rate determined by an index plus a margin (we utilize Prime).
However, we'd like to lower the margin for the time being but not actually get rid of it. Basically, calculate the rate with a lower index for now but keep the existing margin in place for the future. This would seem to be a change in the interest of the borrower as it will allow a lower rate.
Is a Truth-in-Lending disclosure for HELOC the same as the Initial Disclosure?
We have an application that started as an $18,000 home equity line of credit (HELOC) for home improvements. The bank counteroffered the applicant a closed end mortgage in the amount of $8,671 and they accepted that offer and their government monitoring information was then collected and disclosures were sent. Days later the applicants called back and stated after further consideration they were not comfortable with doing the closed end mortgage, which raises a couple questions: 1 – do we go back to the original request of a HELOC and deny the HELOC application for excessive LTV listing our counteroffer; or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?