I POSTED THIS IN THE FLORIDA FORUM AND HAVEN'T RECEIVED A RESPONSE YET....IS THERE ANYONE WHO CAN HELP WITH THIS?....

We recently discovered that our system will allow us to skip-a-payment on an interest only HELOC by moving the accrued interest to "Other charges." What this effectively does is move it so the borrower can skip a month and whenever a payoff is requested, the accrued interest that was moved to "Other charges" will show up in the payoff amount. It doesn't affect the principal balance. This is being done to help the borrower who is having financial difficulty at this time.

We do not have any particular agreement for the borrower to sign. Should we? And, are there any other disclosure requirements that we must be mindful of?

This would be a payment deferment and payment deferments are generally regulated by state law. Usually there is some sort of deferment agreement required.

Since these are HELOCs, if you are extending the maturity then the flood rules kick in for both the determination form and also the notice requirements if the property is located in a SFHA.