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Imperial Plumbing CoInc

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Symbol;">· The Credit Union received the application for the home equity line of credit (HELOC) on Friday, 10/9/and sent out a conditional Home Equity Approval Letter dated 10/12/ The conditional approval letter states, “Final approval is subject to acceptability of collateral to comply with Hawaii State Federal Credit Union’s guidelines.” · Because the loan was considered a Jumbo HELOC (loan amount greater than $250,000) the Credit Union guidelines states the Jumbo HELOC must be in 2nd lien position only The applicant’s intent was to pay off an exist [redacted] HELOC at [redacted] ***, which would have placed the Jumbo HELOC in 1st lien position · On 10/13/2015, the Credit Union loan officer communicated to the applicant that the Credit Union could not do the loan because the loan did not comply with our guidelines for a Jumbo HELOC · The Credit Union does not agree that there was any advertising or deceptive practices All marketing materials and brochures go through a compliance/legal review prior to publication Guidelines and requirements for a particular loan product are not generally disclosed in marketing materials, nor would it be practical to do so Disclosures and underwriting guidelines are provided throughout the loan application process as required · The Credit Union does not agree that compensation is in order due to any delay on the Credit Union’s part The loan application was received by the Credit Union on Friday, 10/9/and the applicant was notified on Tuesday, 10/13/that the Credit Union could not do the loan

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