Compliance Q&A: HELOC and an Access Device

Question: Can a bank provide an access device for a home equity line of credit (HELOC)?

Answer: This is permissible, with several risk considerations for the bank. Under Regulation Z, § 1026.2(a)(15)(ii), a debit card that can access a HELOC is a credit card. Additionally, § 1026.12(d)(1), further prohibits the bank from exercising the right of setoff for credit card balances. Therefore, whereas a HELOC without a credit card generally provides a right of setoff, subject to certain requirements, the bank loses this right when providing a debit card to access a HELOC.

Regulation Z, § 1026.2(a)(15) –

Regulation Z, § 1026.12(d) –


Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email and ask for our Membership Team.

Not a member? Learn more about membership with Compliance Alliance by attending one of our live demos: