Fundamentals of Open-End Credit

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Printed Item No: M-OEC
Price: $155/$140

DESCRIPTION:

Consumer lending has undergone many changes within the past few years. Although the emphasis of most of these revisions were on closed-end consumer transactions, especially mortgage loans, financial institutions also originate open-end transactions, also known as lines of credit, including Home Equity Lines of Credit (HELOCs). Like closed-end mortgage loans, HELOCs are subject to a number of newer rules (including rules normally found under the closed-end requirements!). Financial institutions must be aware of those requirements that have existed for a while, as well as the newer obligations. This manual will review the open-end requirements and issues under various laws (e.g., What is the “outstanding principal balance” for flood insurance determinations?), but focusing on the Truth-in-Lending Act/Regulation Z. The manual will provide detailed analysis of the rules and serves as a valuable reference tool.

 

The manual includes discussions of:

Traditional open-end rules, including periodic statements and billing error rights:

  • Account opening statements
  • Periodic statements
  • Billing error rights and resolution
  • Change in terms
  • ECOA

Credit cards – an overview of the complicated requirements, including:

  • Application and solicitation disclosures
  • When and how an interest rate can be increased
  • Ability-to-repay
  • Limitations on over-the-limit fees

HELOCs

  • All TILA/Regulation Z requirements, Flood, RESPA, ECOA
  • Limitations
  • How HELOCs are similar to, but also different from, non-dwelling open-end transactions
  • At application disclosures
  • Change in terms
  • Closed-end rules that apply to HELOCs

In addition to compliance requirements, various agency guidance

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