TIL/GFE Disclosures for HELOC to Purchase Home

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Question:

We are doing a Home Equity Line of credit to purchase a home, do we need to do TIL and GFE disclosures? Or are they exempt?

Answer:

The fact that the HELOC is being used as purchase money does not change the disclosure requirements for the HELOC. HELOCs get a special program disclosure at time of application instead of a GFE/Early TIL and get TIL disclosures incorporated into the HELOC note at closing.