Answer:
The timing for delivery on HELOCs is no different than your timing for closed-end dwelling secured loans.
Reg. B's 202.14(a)(2)(i) says the notice may be given any time during the application process, but no later than when you provide notification of your decision under the requirements of 202.9. Unless you notified the applicant of your approval decision, and closed the loan the same day, then giving it at the time of closing is too late in my opinion.
First published on BankersOnline.com 5/23/05