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Fed issues plan to extend TILA Consumer Leasing Act
WASHINGTON (12/14/10)--The Federal Reserve Board Monday proposed two rules that would expand the coverage of consumer protection regulations to credit transactions, as well as double the dollar amount of consumer leases that would be covered. The proposed rules would amend Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank ACT). Starting July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (TILA) and the Consumer Leasing Act (CLA) apply to consumer credit transactions and consumer leases up to $50,000, compared with $25,000 currently. This amount will be adjusted annually to reflect any increase in the Consumer Price Index. TILA requires creditors to disclose key terms of consumer loans and prohibits creditors from engaging in certain practices with respect to those loans. Currently, consumer loans of more than $25,000 are generally exempt from TILA. However, private education loans and loans secured by real property, such as mortgages, are subject to TILA regardless of the amount of the loan. The CLA requires lessors to provide consumers with disclosures regarding the cost and other terms of personal property leases, such as an automobile lease. The Fed said comments must be submitted by Feb. 1, 2011. Use the resource link to read the Fed proposal and for more information on the affected regulations. The notices that will be published in the Federal Register are attached. Comments on the proposals must be submitted by the later of 30 days after publication in the Federal Register or February 1, 2011.
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