HELOC Program Disclosure

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  • #6337

    When selecting a margin for the 15 year history we must select a margin we have “used in the last 6 months”. Does that mean a margin actually charged on a loan originated, or a margin available from our pricing matrix? For one of our HELOC products we happen to have several applicable margins depending on the borrowers credit score. We have only originated 1 in the last 6 months due to other competing products and wonder if we must use the margin from this 1 loan, or would we be able to select a margin in the middle of the possible margins for use in the program disclosure?


    My interpretation of this is that it needs to be a margin that was actually used within the last 6 months.

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