[Susan]

This is an unusual request for this forum but I was hoping to locate a peer at a Jack Henry Silverlake bank that has evaluated the statement capability as a HELOC moves from draw to repayment. Currently we have a balloon product but there is now a product proposal under review that would incorporate both a draw and a repayment period. Based on what we do now, I see no way to continue producing an open end statement during the repayment phase. I have reviewed comment 1026.40 – 5 and so understand when either the open end or closed end sections of the regulation apply. If we combine both the draw and repayment phases into our open end plan, we need to be able to produce the open end statement thoughout the plan. Has anyone addressed this specifically with Jack Henry Silverlake? In general, what approaches have you adopted to meet the limitations of your system? Would we be restricted to always refinance to a closed end product? Any systems NOT have a problem handling this transition and still producing the required statements? Suggestions and explanations, as always, are welcome! Thanks.

[rcooper]

Susan,
We will present your request during our CMG meetings this week in hopes of finding other members who may be able to share information with you.
Thank you.

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