Home Equity Line of Credit - Open End

Answered by:

Question:

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?

Answer:

It does not have to be disclosed under Regulation Z, but I would consider the possibility of claims of unfair and deceptive advertising practices in the current environment.

First published on BankersOnline.com 3/02/09