Consumer Lending
Recent Activity
What: The Federal Reserve Board (FRB) has published a final rule amending Regulation Z. This amendment implements changes from the Dodd-Frank Wall Street Reform and Consumer Protection Act that amended the Truth in Lending Act. The amendment affects the threshold dollar amount used to determine whether a consumer-purpose transaction is subject to Regulation Z. The threshold for exempt consumer credit transactions has been increased from $25,000 to $50,000.
When: The rule is effective July 21, 2011.
For further information, follow this link to ComplianceHeadquarters.
Historical Activity
What: The Federal Reserve Board (FRB) has issued an interim rule that revises the disclosure requirements for closed-end consumer loans secured by real property or a dwelling. The term “dwelling” includes personal property such as a manufactured home or trailer if used as a residence.
When: This interim rule is effective on October 25, 2010, with compliance optional until January 30, 2011. The FRB is accepting comments on the interim rule until November 23, 2010 before considering the adoption of a permanent rule.
For further information, visit the Mortgage Reform Tab.
What: The Regulation Z proposal to revise the closed-end mortgage disclosure requirements also contained changes to consumer disclosures in non-mortgage settings.
- Creditor identity would become a segregated disclosure and would need to appear inside the “fed box.” This would apply to all closed-end credit disclosures.
- Additional disclosures would be required if the creditor is selling credit insurance/debt cancellation or suspension products. The creditor would be required to disclose additional information about whether the consumer meets the age and/or employment eligibility requirements associated with the credit insurance, debt cancellation, or debt suspension product being sold. This change would affect both closed-end and open-end credit.
When: The comment period ended December 24, 2009. The FRB has not established timelines yet; we expect final regulations in 2010. The effective date is still in question.
