Fundamentals of Open-End Credit
To order a printed manual, please click here.
Or you may click here to download an order form.
Printed Item No: M-OEC
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
Credit cards – an overview of the complicated requirements, including:
- Application and solicitation disclosures
- When and how an interest rate can be increased
- Limitations on over-the-limit fees
- All TILA/Regulation Z requirements, Flood, RESPA, ECOA
- 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