At this year’s Regulatory Compliance Seminar that will be held in Savannah, Georgia, from October 1st through the 4th, the NAFCU Compliance team will be unveiling an advertising workshop solely related to HELOCs and closed-end mortgage loans. There are still a few seats left for the workshop session scheduled for the afternoon of Thursday, October 4th. In anticipation of the workshop, I wanted to provide a brief refresher on the trigger terms associated with HELOCs.Section 1026.16(b)(1) of Regulation Z describes the general trigger terms that apply to all open-end credit, and section 1026.16(d)(1) contains additional disclosures that are required for HELOCs. With respect to HELOCs, section 1026.16(b)(1) indicates that “[a]ny term required to be disclosed under §1026.6(a)(1) or (a)(2) set forth affirmatively or negatively in an advertisement for a home-equity plan subject to the requirements of §1026.40 triggers additional disclosures under this section.” Those same terms are identified in section 1026.16(d)(1). Section 1026.16(d)(1) also includes payment terms of the HELOC as a trigger term. In other words, if you advertise the circumstances under which a finance charge will be imposed and how the finance charge will be determined – terms required to be disclosed under section 1026.6(a)(1) – or the amount of any charge other than a finance charge that may be imposed as part of the plan – what is required by section 1026.6(a)(2) – or the payment terms of the plan, then you trigger the additional disclosures set forth in sections 1026.16(b)(1)(i) through (iii) and sections 1026.16(d)(1)(i) through (iii): ShareShareSharePrintMailGooglePinterestDiggRedditStumbleuponDeliciousBufferTumblr continue reading »
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