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Required Checking Accounts For HELOCs

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Question: 
For our consumer Home Equity Lines of Credits, can we require the customer to have a checking account at our bank and that all advances must go into that checking account? If so, does this need to be disclosed to them?
Answer: 

Yes, you just can't require repayment from a bank account. See the Commentary to Section 205.10(e)(1):Loan payments. Creditors may not require repayment of loans by electronic means on a preauthorized, recurring basis. A creditor may offer a program with a reduced annual percentage rate or other cost-related incentive for an automatic repayment feature, provided the program with the automatic payment feature is not the only loan program offered by the creditor for the type of credit involved.

First published on BankersOnline.com 09/2/02

First published on 09/02/2002

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