[Kgreene]

Our institution is new to HELOC loans. We are just starting out and have a question. We will be charging the customer a $395.00 origination charge at closing. If we allow the customer to draw that fee off their line we are understanding the regulation requires this fee to be reflected on the billing statement. Can we show the $395.00 as disclosed at closing for the origination fee or do we have to disclose the breakdown of our costs to do the loan that come out of the origination?

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