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CU comment sought on Reg Z closed-end mortgage rules
WASHINGTON (9/4/09)--The Credit Union National Association (CUNA) has issued a regulatory comment call on the Federal Reserve's proposal that will revise the disclosures that lenders must provide in connection with mortgage loans. The proposal will require that Fed-published documents be given to consumers at the time of application and will revise the other current disclosures, which must be provided within three days after application, as well as three days before loan consummation. This information is intended to outline additional information about certain loan features, especially in connection with adjustable rate mortgages. These changes, which would apply to disclosures for all closed-end credit transactions secured by real property, would also revise the annual percentage rate (APR) calculation to include most fees and settlement costs, many of which are currently excluded from the APR. The proposal will impose eligibility and disclosure requirements for credit insurance, debt cancellation, and debt suspension coverage. In addition, the Fed would require lenders to notify borrowers 60 days before any changes to their monthly payments on adjustable-rate loans are made. The Fed currently rules require lenders to give consumers 25 days of advance notice. Comments are due to CUNA by Dec. 10, and should be submitted to the Fed on Dec. 24. To view the CUNA comment call, use the link.


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