I have been researching an issue for my bank in regards to providing periodic statements after a HELOC matures. Are FIs required to provide periodic statements post maturity on HELOCs? The Promissory Notes clearly states that the entire loan balance (principal and interest) is due and payable at maturity. I don't see it necessary to continue to send monthly periodic statements and this has also added confusion to the client. I do not see that this is addressed within Reg Z. Am I looking in the wrong place?
For HELOC early disclosures (ex. appraisal notice, consumer credit score disclosure, acknowledgment of receipt of counselor list, home equity application disclosure,) is the borrower required to sign these forms to acknowledge receipt, or can we have copies and a letter listing them out as proof in the file that they were delivered?
Do bankers collect government monitoring information on 2nd home HELOCs?
Do we need to send a Good Faith Estimate on a new HELOC, or would this need a loan estimate and a closing disclosure?
I am doing a HELOC for under $250,000 as a 1st Deed. Is a full interior appraisal required or can a desk-top valuation be done?
Does a Right of Rescission for a HELOC have to state that the loan is an open-end loan? All the rescission forms in Appendix G include reference to an open-end loan.
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?