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CUNA comments on Reg Z changes
WASHINGTON (2/2/11)--The Credit Union National Association (CUNA) in a comment letter to the Federal Reserve said it does not support certain Regulation Z changes that go beyond the scope of a new $50,000 threshold for consumer credit disclosures. Specifically, CUNA said that changes beyond the scope of the $50,000 threshold increase would impose additional compliance and continuous monitoring costs. Consumer credit transactions of up to $25,000 are currently subject to several disclosure requirements under the Truth in Lending Act (TILA) and Regulation Z. Private education loans and loans secured by real property, such as mortgages, are subject to TILA regardless of the amount of the loan. Regulation Z implements the Home Ownership and Equity Protection Act (HOEPA) by adjusting the thresholds used to determine which loans are covered under HOEPA. CUNA urged the Fed not to adopt language that would require an initial extension of credit to be advanced at account opening. CUNA also supported Fed clarifications that would specify that closed-end loans would qualify for exemptions based on either credit extensions or a loan commitment at consummation in excess of the threshold, regardless of subsequent changes in the threshold or account balance. Under the Reg Z changes, lenders are required to retain evidence of compliance for 24 months. CUNA urged the Fed to clarify which types of records must be maintained. A similar request has been made in relation to the Fed’s Regulation M proposal. (See related story: Reg M burdens should be minimized, CUNA says) For the full CUNA comment letter, use the resource link.
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