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Are an LE (Loan Estimate) and CD (Closing Disclosure) required to be disclosed for an adjustable-rate home equity plan?

A) Yes
B) No
C) Both a and b
D) None of these

1 Answer

6 votes

Final answer:

For adjustable-rate home equity plans such as HELOCs, a Loan Estimate and Closing Disclosure are typically not required according to TILA, with different disclosure requirements in place instead.

Step-by-step explanation:

The question is asking whether a Loan Estimate (LE) and a Closing Disclosure (CD) are required for an adjustable-rate home equity plan. In situations involving home equity lines of credit (HELOCs), which are a type of adjustable-rate home equity plan, neither an LE nor a CD is typically required. Instead, the Truth in Lending Act (TILA) requires creditors to provide a HELOC applicant with a brochure describing the plan's terms and costs, as well as a disclosure statement containing information about the HELOC, such as the annual percentage rate (APR), payment terms, and any charges associated with the account. In contrast, for most closed-end residential mortgage loans, both the LE and CD are required by the TILA-RESPA Integrated Disclosure rule (TRID) to ensure consumers are well-informed about their loan terms and closing costs. Therefore, the correct answer to the student's question is B) No, and they are not mutually exclusive either.

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