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CU comments wanted on Fed disclosure plan
WASHINGTON (12/18/08)—To implement mortgage disclosure rules brought about by this year’s Mortgage Disclosure Improvement Act (MDIA), the Federal Reserve Board has proposed changes to its Regulation Z and the Credit Union National Association (CUNA) seeks credit union comment on the plan. In its comment call, CUNA reminds credit unions this is just the beginning of changes to come. The Fed is in the process of reviewing Reg Z in its entirety and will issue more changes to the mortgage disclosure provisions sometime next year. For now, theThe MDIA requires creditors to mail or deliver good faith estimates of mortgage loan costs within three business days after receiving a loan application and before any fees are collected, other than a reasonable fee for obtaining a credit report. The term “business day” is defined as any day in which the lender’s office is open for business. CUNA notes these early disclosure provisions are consistent with the Fed’s recent final rule that amends the Home Ownership Equity Protection Act (HOEPA), which imposes this requirement for the consumer’s primary home. The MDIA now broadens this requirement to include all dwellings, such as second homes. These requirements will apply to refinancings and home equity loans, but they will not apply to home equity lines of credit (HELOC), which are considered “open-end” loans and not subject to these provisions of TILA and Regulation Z. Use the resource link below to read more about the Fed proposal and to access CUNA’s comment call. CUNA requests comment by Jan. 15. The Fed Wednesday extended its comment period to Feb. 9 from Jan. 23.


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