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If a home equity line of credit customer is not required to make a payment for a period of time, is a periodic statement still required under Regulation Z?

If, due to forbearance or similar promotion, a home equity line of credit customer is not required to make a payment for a period of time (e.g., three months), is a periodic statement still required under Regulation Z?

Yes. Under, §1026.5(b)(2)(i) and the related commentary, periodic statements are required in any billing cycle on which a finance charge has been imposed or on which an account has a debit or credit balance of $1 or more. Simply removing or not imposing interest does not, by itself, eliminate the requirement to provide a statement. Exceptions to this statement requirement are limited to situations where an account is deemed “uncollectible,” delinquency collection actions have started, the account has been charged off and no additional fees or interest will be charged, or furnishing the statement would violate federal law. Moreover, other provisions of the regulation may be affected by the date the periodic statements are mailed or delivered, such as §1026.13 which relating to billing error resolutions. (June 2020)

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