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TIL/GFE Disclosures for HELOC to Purchase Home

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We are doing a Home Equity Line of credit to purchase a home, do we need to do TIL and GFE disclosures? Or are they exempt?

The fact that the HELOC is being used as purchase money does not change the disclosure requirements for the HELOC. HELOCs get a special program disclosure at time of application instead of a GFE/Early TIL and get TIL disclosures incorporated into the HELOC note at closing.

First published on 05/18/2015

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