ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

Compliance question of the month: Must banks provide a homeownership counseling notice to all HELOC applicants?

June 7, 2023
Reading Time: 1 min read

A banker recently submitted the following query: My bank provides a homeownership counseling notice that contains a list of counseling service organizations available in the applicant’s location only if, after application, it is deemed to be a high-cost mortgage, as defined in §1026.32(a)(1) of Regulation Z (Truth in Lending Act). We have been discussing internally whether the notice must be provided to all home equity line of credit (HELOC) applicants or only to high-cost mortgage applicants

QAre banks required to provide a notice to all HELOC applicants, even if the HELOC is not a high-cost mortgage?

AYes. The notice must be provided to any applicant for a “federally related mortgage loan.” Section 1024.20(a) of Regulation X (Real Estate Settlement Procedures Act) requires that a list of homeownership counseling organizations be provided no later than three business days after receipt of an “application.” Application is defined as submission of financial information in anticipation of a credit decision relating to a “federally related mortgage loan,” which generally is a loan secured by a first or subordinate lien on residential real property that also meets certain other requirements. For additional guidance, see Section 5.1 “What homeownership counseling requirements apply to creditors regardless of whether or not they make high-cost mortgage?” in the Consumer Financial Protection Bureau’s Home Ownership and Equity Protection Act (HOEPA) Rule – Small entity compliance guide.

For more information, contact ABA’s Mark Kruhm.
Please note that this section is not a substitute for professional legal advice.

Tags: ComplianceHELOCsMortgageRESPA
ShareTweetPin

Related Posts

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: February 9

Uncategorized
February 9, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

U.S. Supreme Court declines to weigh class standard in TCPA junk fax lawsuit

U.S. Supreme Court declines to review Eleventh Circuit decision reviving cash-advance lawsuit against Citigroup

Uncategorized
February 2, 2026

The U.S. Supreme Court declined to review an Eleventh Circuit decision that revived a lawsuit alleging Citigroup operated a cash-advance fraud scheme.

Seventh Circuit revives CFPB’s lender redlining lawsuit

U.S. Supreme Court declines to review reverse-redlining lawsuit

Uncategorized
February 2, 2026

The U.S. Supreme Court declined to review a Second Circuit decision affirming a New York federal court judgment that awarded compensatory damages to four homeowners after determining Emigrant Mortgage Company Inc. engaged in “reverse redlining.”

ABA, trade groups: CFPB has no authority to enact rule limiting arbitration 

U.S. Supreme Court declines to review Georgia arbitration opt-out ruling under the FAA

Uncategorized
February 2, 2026

The U.S. Supreme Court declined to review a Georgia appellate court decision that allowed a proposed class representative to opt out of arbitration on behalf of all proposed class members, leaving in place a ruling that the FAA...

ABA comments on FHFA’s re-proposed eligibility standards for enterprise single-family seller/servicers

Ninth Circuit affirms FHFA funding mechanism

Uncategorized
February 2, 2026

In a unanimous decision, a Ninth Circuit panel affirmed the dismissal of a lawsuit against FHFA, ruling that its funding mechanism is constitutional.

Second Circuit confirms recklessness satisfies willfulness standard for FBAR penalties

Second Circuit confirms recklessness satisfies willfulness standard for FBAR penalties

Uncategorized
February 2, 2026

In a unanimous decision, a Second Circuit panel affirmed a New York federal court’s ruling that enforced civil penalties against Juan and Catherine Reyes for willfully failing to file Reports of Foreign Bank and Financial Accounts.

NEWSBYTES

Senate fails to reach funding deal on DHS

February 12, 2026

Existing home sales decreased 8.4% in January

February 12, 2026

Report: Deepfake detection efforts foiling fraudsters

February 12, 2026

SPONSORED CONTENT

How Instant Payments Can Accelerate B2B Payments Modernization

How Instant Payments Can Accelerate B2B Payments Modernization

February 3, 2026
Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

February 1, 2026
Planning Your 2026 Budget? Allocate Resources to Support Growth and Retention Goals

Why Every Digital Interaction Defines Your Brand Experience

February 1, 2026
Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

November 1, 2025

PODCASTS

Podcast: How the SCAM Act would encourage platforms to go after scammers

February 4, 2026

A new kind of ‘community bank’ for small businesses

January 22, 2026

Podcast: A Lone Star banking perspective

January 15, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.