No, we do not believe that thirty days advance notice is required before rate changes resulting from the interest calculation disclosed under a HELOC’s account agreement. The Illinois Financial Services Development Act requires thirty days advance notice before amending a HELOC agreement. That provision would not apply in this case because the agreement is not being amended; the rate is changing due to a change in the index governing the rate, not an amendment of the account agreement.

For resources related to our guidance, please see:

• Illinois Financial Services Development Act, 205 ILCS 675/8(c) (“Amendment of agreement governing revolving credit plans other than credit card accounts. . . . (c) If such amendment has the effect of increasing the interest or other charges to be paid by the borrower, the financial institution shall mail or deliver to the borrower, at least 30 days before the effective date of the amendment, a clear and conspicuous written notice . . . .”)