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For HELOCs, creditors must disclose and itemize points, loan fees, and similar finance charges that are paid out of the first advance on the first periodic statement. Must any other charges that are part of closing costs that are paid out of the first advance also be disclosed and itemized?

I understand that for home equity lines of credit creditors must disclose and itemize on the first periodic statement points, loan fees, and similar finance charges that are paid out of the first advance. Must any other charges that are part of closing costs that are paid out of the first advance also be disclosed and itemized?

No. Comment 8 to §1026.7(a)(6)(i) of Regulation Z (Truth in Lending Act) requires that points, loan fees, and “similar finance charges” be disclosed on the first periodic statement if they are paid out of the first advance. However, if the fees are not “similar finance charges,” they need not be disclosed on the periodic statement even if they have been paid out of the first advance. However, all finance charges and other charges, including “closing costs or settlement costs” that are “imposed during the billing cycle” must be disclosed on the periodic statement. (Feb. 2021)

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