Since 1989 Regulation Z has required financial institutions to develop special home equity lines of credit (HELOC) program disclosures. Many other regulations also apply to HELOCs, frequently with provisions that are unique for this type of credit. HELOCs are complicated. There are layers of disclosures provided at application, closing and throughout the life of the line. There are restrictions that apply to HELOCs that do not apply to other types of loans. There are unique portfolio management issues such as how to handle lines that are nearing the end of their draw periods, and limitations on selecting a new index when the existing index expires.
This two-hour program explains how to develop, maintain and audit HELOC program disclosures and provides an overview of other required disclosures. The program explains the rules, reviews typical problems, and provides steps to assure ongoing compliance.
Participants receive a detailed manual that serves as a handbook long after the program is completed.
Upon completion of the program attendees understand
- Which transactions are covered by or exempt from Regulation Z;
- The differences between open-end and closed-end credit;
- The specific requirements for Home Equity Plans:
- Timing of the application disclosures;
- Content of the application disclosures;
- The brochure entitled “What You Should Know About Home Equity Lines of Credit;”
- Limitations on Home Equity Plans;
- The general rules for open-end credit:
- Account opening disclosures;
- Periodic statements;
- Subsequent disclosure requirements;
- Billing error resolution;
- Right of rescissions, including Juneteenth issues;
- Advertising; and
- Other laws and regulations such as flood insurance requirements and the Real Estate Settlement Procedures Act (Regulation X).
The program is designed for loan officers, compliance officers, loan support staff, marketing staff, auditors, and any others with responsibilities related to the origination and maintenance of HELOCs.