Our HELOC's are accessed by checks. These checks go thru a DDA account (sweep)issued in the customers name. Each month the DDA account should have a "0" balance. Is it necessary to send these DDA accounts to customers. We send monthly HELOC stmt that basically shows all the transactions that "sweep" thru DDA accounts.

Reg Z 226.8 indicates that you probably need to provide the DDA statements, otherwise, you will not see the individual transactions as required.

226.8 states:
Identification of Transactions (01/01/93)

The creditor shall identify credit transactions on or with the first periodic statement that reflects the transaction by furnishing the following information, as applicable.16

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16 Failure to disclose the information required by this section shall not be deemed a failure to comply with the regulation if:

(1) The creditor maintains procedures reasonably adapted to obtain and provide the information; and

(2) the creditor treats an inquiry for clarification or documentation as a notice of a billing error, including correcting the account in accordance with §226.13(e). This applies to transactions that take place outside a state, as defined in §226.2(a), whether or not the creditor maintains procedures reasonably adapted to obtain the required information."

I don't think so. We use to process the same way. You are just using the DDA processing system and a "shadow" DDA account (I am assuming). As long as you are passing the check number to the HELOC statement - you should be fine.

Thanks - That's exactly what we do.

I only thought that's what we do. Come to find out, the check number is not on the HELOC stmt.

Found out ck number is not reflected on HELOC stmt. Is that a problem?

What does it show in the description?

the date - the $ amount - the description is "advance"