Documents for HELOC Open End that Matured

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Question:

We have a HELOC open end that matured last month. The loan officer wants to set this up as a 30-year ARM with a 1-year maturity. What documents must we have? Does RESPA apply?

Answer:

I think you mean a 30-year amortization with a 1-year maturity which would make it a balloon loan. This will be closed-end credit and you have to follow all the applicable regulations. TIL (MDIA, HOEPA, HPML), RESPA, HMDA, Flood, Reg B, etc.

If you decide to refinance it as another HELOC then you have to provide all the applicable disclosures just as if it was a new HELOC request since it has matured.

First published on BankersOnline.com 8/29/11