We are not aware of any restrictions on financing closing costs, and we agree that the closing costs should be itemized on the HELOC’s first monthly statement (though they do not need to be factored into the annual percentage rate). 12 CFR 1026.7(a)(6)(i)Comment 8, Start-up fees, Official Staff Commentary. Given that the Regulation Z Official Staff Commentary contemplates a loan in which “points, loan fees, and similar finance charges” are “financed as part of the plan,” we do not believe that federal law would prohibit this practice.

Illinois law also permits rolling finance charges into HELOCs. The Illinois Financial Services Development Act confirms that Illinois financial institutions may charge any fees or charges and impose any terms and conditions that a customer agrees to. 205 ILCS 675/4. The Act states that “[n]otwithstanding the provisions of any other laws in connection with revolving credit plans, any financial institution may . . . charge and collect interest and other charges . . . as the financial institution and borrower may agree upon from time to time.” 205 ILCS 675/4. It also specifically authorizes financial institutions to charge several types of fees “as interest, in such manner or form as the plan may provide.” Those fees include annual or periodic fees, transaction charges, late fees, returned payment charges, over limit charge, and “fees for services rendered.” 205 ILCS 675/6.