Compliance Blog

Aug 10, 2009
Categories: BSA Consumer Lending

HELOCs; I need your help

Posted by Anthony Demangone

The Federal Reserve Board recently published a consumer-oriented list of "tips" regarding HELOCs.  Specifically, the Fed issued the 5 tips to help consumers understand their rights and lender responsibilities when HELOC lines are frozen or reduced.  Access the Fed's press release here, which contains a link to the "tips." 

I mention this because this is the type of thing that will be picked up by financial columnists and news wire services.  Your members very well could read this tip sheet, so you should as well.  Tip #2 directs consumers to contact their lender should their line be frozen or reduced.  I would read this document closely if your credit union has or will reduce or freeze HELOCs.  And be sure your front-line staff can respond to these tips assuming members will read them and then contact your shop.

Regarding HELOCs, don't forget that the Fed has a proposed rule out there to amend its HELOC rules.

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I need your help in two areas. 

  • I'll be presenting a "BSA Update" for NAFCU on September 30.  Go here to see what I'll yabba dabba about and to sign up, if you are so inclined.   As part of the webcast, I'd love to hear what your examiner stressed over during the BSA portion of your most recent exam.  I've spoken with folks at NCUA and FinCEN to get their take, but I always like to hear it from you.  I'll take the responses and share what I learn.  Feel free to email me (respond to the daily email or email me at ademangone (at) nafcu.org.).
  • What should we focus on next within this Blog?  The HOEPA changes that take effect in October?  RESPA?  Something else? Let me know your thoughts.  Either email us or leave a comment on the blog.