Question and Answer

Are there any requirements for specific disclosures on periodic home equity loan statements for consumers in bankruptcy? 12 CFR Part 1026.41 (Regulation Z) has requirements for closed-end consumer credit transactions but unclear about HELOCs.

Our review of Reg Z for open-end credit periodic statement requirements (1026.7) found nothing specific noted relating to loans in bankruptcy. The requirements only apply to closed-end credit under 1026.41.

However, there may be state specific rules regarding statements and borrowers in bankruptcy. We recommend reaching out to your legal counsel or state banking association to validate there are no requirements at the state level.

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