Should a bank allow ACH transactions on home equity lines of credit that are generally accessed by a check? Consider that some checks are converted to an ACH transaction. Under what Regs would these types of transactions be governed and what is the risk to the bank and to the consumer?
In providing the HELOC early disclosures with an Internet application, is it acceptable to provide the disclosures via a link (before the applicant gets to the application) which link the applicant can bypass?
Please provide some of the pros and cons -- particular as related to fraud risk -- of providing access to Home Equity Lines of Credit (HELOCs) via debit card.
We are thinking about allowing customer to complete a loan application on the Internet and submit it back to the bank via Internet. Must we provide the appropriate disclosures electronically through the Internet? If so what about the new federal consumer credit score disclosure? We will have to run credit before we can get that to the applicant.
With an emailed application that has been faxed in by the borrower, what are the compliance guidelines for the GFE and TIL?
We want to begin offering debit cards tied to home equity lines of credit. To do so, we must open a "dummy" checking account (a system requirement I think). Do we have to give normal checking account disclosures for this dummy account? I do believe we need to give Reg E disclosures, but am not sure about any of the others.
We are in the process of setting up the process that allows our customers to access their HELOCs via a Visa Card. The card is actually a debit card though - in that it first accesses the customer's DDA account. That particular DDA account is set up and used only for this process, and works in the following manner: The customer uses card that taps into a DDA account that has a zero balance. The account automatically advances the amount of the transaction into the DDA account. So the account is debited, shows a negative balance, which is then zeroed out by the auto transfer from the HELOC. My question is two fold: With this type of process is our card considered a 'credit card'? And if not, and it is considered an actual debit card, can we send cards to existing customers unsolicited?