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Closed-end Line of Credit - Fed Box Disclosures

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We have a personal closed-end line of credit with a term of nine months. We are anticipating multiple advances during the term of the credit up to the maximum amount. According to 226.17(c)(6)(i) a series of advances under an agreement to extend credit up to a certain amount may be considered as one transaction. When disclosing the Fed Box items, APR, Finance Charge and total of payments must the "e" (for estimate) be placed in each of these boxes?

Although I would not describe this as a "line of credit" (that term is usually reserved for open-end credit), I agree that the APR, finance charge and total of payments calculations using the "one transaction" option in Section 226.17(c)(6) would perforce result in estimates, and each of those numbers should be identified as an estimate in your disclosures.

First published on 7/23/07

First published on 07/23/2007

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