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Modification/Renewal Fees for Consumer Loans

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  • May 7, 2011 at 2:09 pm EDT #2329
    kseyle
    Member

    We currently do not charge a fee to consumers for a renewal or modification of their loan. Several of our officers think it is a violation of Reg Z and that we would need to redisclose if we do this – I disagree with them. Is anyone doing this? If so, can you help me find within the REG that it is okay to do this? I have looked and cannot find it. Thank you!!

    May 9, 2011 at 6:24 pm EDT #2699
    JGo9
    Participant

    I’m a bit unclear on your question. If you would please provide some more detail.

    A general rule of thumb is if you provide documents then you need to redisclose; reguardless of the fee or charges.

    The term renewal means different things to different banks; so please define or give us an example.

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