HELOC Itemized Disclosures

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Question:

I am looking for some clarification on disclosing the finance charges section which states the components of the finance charge shall be individually itemized and identified to show the amount(s). Start up fees - charges are financed as part of the plan, including charges that are paid out of the first advance, charges must be disclosed. My question is, we have a HELOC that financed all fees into the loan. Our operations department was told to list them individually. However, they combined the Recording and E-Recording fee as a single total, with the description of Recording Fees. Then the Title Insurance fee and Title Services fee were shown as a combined total with the description, Title Insurance Fee. Would this suffice or should they truly be separated out? My recommendation was to list them all out, to mitigate confusion but our operations team is unsure if we can add the additional fee modifiers to our banking system.

Answer:

There are no specific itemization requirements as long is you give them sufficient information to reconcile the charges back to the account opening documentation.

1026.8(b) Nonsale credit. For each credit transaction not involving the sale of property or services, the creditor must disclose a brief identification of the transaction; the amount of the transaction; and at least one of the following dates: The date of the transaction, the date the transaction was debited to the consumer's account, or, if the consumer signed the credit document, the date appearing on the document. If an actual copy of the receipt or other credit document is provided and that copy shows the amount and at least one of the specified dates, the brief identification may be omitted.