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Customer Appreciation HELOC Offer

Answered by: 
John Burnett

Question: 
I have looked high and low for guidance on this and am having little success. We want to offer to "waive one year annual fee on new or existing Home Equity Lines of Credit" to our long time (20+ years) customers. Reg Z states that any negative or positive fee information is a triggering term, but I don't know if it applies in this situation. This will be sent as a statement insert to those customers only. Our HELOCs are open-ended credit products. Is this considered a triggering term in this situation?
Answer: 

If you're offering this only to current HELOC customers, you aren't promoting your HELOC product, so I don't think it's an ad, but if your targets are all of your 20+ year customers, you're advertising, regardless of how you send the insert to your customers. Mentioning a waiver of a participation fee in such an ad pulls the trigger under 226.16(d)(1).

First published on BankersOnline.com 4/07/08

First published on 04/07/2008

Filed under: 
Operations
Filed under operations as: 
HELOC
Home Equity
IT

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