Do the regulations apply to an open-end credit plan?
A. Yes, the regulations apply to secured open-end credit plans. That is a change made by the amended regulations. To emphasize this change the word “unsecured” was added to 209 CMR 32.32(1)(b)2. Therefore loans not covered by the amended 209 CMR 32.32 are a reverse mortgage transaction and an unsecured open-end credit plan.
