Homeownership Counseling Notices for HELOCs

Question:

Does the homeownership counseling notice need to be provided on open-end home equity lines of credit? This is a RESPA requirement, and our HELOCs are not subject to RESPA.

Answer:

Yes the counseling notices required under 1024.20 do apply to HELOCs. The only exemptions to the requirements under 1024.20 are reverse mortgages and timeshares. However, for a federally related mortgage loan that is a home-equity line of credit subject to Regulation Z, 12 CFR 1026.40, a lender or mortgage broker that provides the loan applicant with the list of homeownership organizations required under this section may comply with the timing and delivery requirements set out in either paragraph of this section or 12 CFR 1026.40(b).