We just started reporting HELOC loans for HMDA. I am having difficulty figuring out rate spread. Do you even need to report rate spread for HELOC loans?
We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?
The consumer has an initial advance of $1,000 from their HELOC and it is deposited in their checking account. Is this practice acceptable in that the loan fee that is subsequently paid from the checking account is clearly paid from the advanced proceeds and it is not identified as a finance charge on their initial billing statement?
We are interested in advertising our introductory interest rate for our HELOC on the side of a bus. Should we treat it just like a newspaper advertisement with all of the same disclosures based on the triggers?
Must a Home Equity Early Disclosure be given to a borrower three days prior to closing or within three days of application?
If a customer pays all the HELOC fees in cash, are we required to include detail of the fees paid on the first statement?
The bank would like to target unused HELOCs and offer these clients a promotional rate of 2.99% for six months to use the line. After six months, if the advance(s) are not repaid, the rate would convert to the contract rate. What disclosures would be required upfront? Would we have to specify the contract rate that each individual HELOC would convert back to or can we just give a general disclosure abuot converting back to contract rate?
We are currently advertising that we have no closing costs associated with our HELOC products. Is it true that as of October 1, 2009, if we continue to advertise no closing costs this becomes a trigger term and requires additional disclosures? If so, what additional disclosures are required?
The appearance of "triggering terms" in a HELOC ad require the disclosure of a maximum rate, but there is no mention of a floor rate. If a HELOC has a floor rate, must it be disclosed in an advertisement? If the floor rate has a range, must the range be shown and the criteria that could affect a borrower's specific rate be mentioned?
We currently have a promotion on HELOCs with a much lower rate than last year. As a part of the promotion, we sent out a direct mail piece to a special group of our current customers. Now we want to follow up this piece with a phone call to have another touch point with our customers to see a better ROI. By regulations standards, can we discuss the rate on the phone with the customers without have to say all of what is in the small print (what is printed in an ad)? What about if we leave a voice mail for the customer?