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A question we received from a member:
I’m trying to find an answer to this question and not finding any concrete answer in Reg Z. I know that HELOCs are not subject to the new “ability to repay” rules. However, are there any regulatory specifications elsewhere in Reg Z for ability to repay HELOCs? I’m not finding it, if there is. Thought I recalled something relative to the credit card act but couldn’t find it.
I believe you are thinking about the High Cost Mortgage requirement under 1026.34(a)(4)(ii). It is linked here: https://www.ecfr.gov/cgi-bin/text-idx?SID=a73fc1358d918790ff49be8da05ce6f6&node=12:8.0.2.8.18.5.1.5&rgn=div8
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