On March 18th the Federal Reserve Board approved a rule amending Regulation Z (Truth in Lending) to clarify prior rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit Card Act). The rule enhances protections for consumers who use credit cards and resolves areas of uncertainty so that card issuers fully understand their compliance obligations. The Credit Card Act requires that, before opening a new credit card account or increasing the credit […]
Category: Truth in Lending
WHAT’S UP WITH ESCROWS
On February 23, 2011 the Federal Reserve Board issued a final rule and requested public comment on a second rule under Regulation Z to revise the escrow account requirements for certain home mortgage loans. The revisions to the regulation, which implements the Truth in Lending Act (TILA), are being made pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. The final rule implements a provision of the Dodd-Frank Act that increases the annual […]
MASSIVE REGULATION Z RULES ARE SHELVED
Recently the Federal Reserve Board announced that it does not expect to finalize three pending rulemakings under Regulation Z prior to the transfer of authority for such rulemakings to the Consumer Financial Protection Bureau (CFPB). The proposed rules were massive. They would have changed all of the rules regarding the disclosures for mortgage loans, both open-end (HELOCs) and closed-end. But we haven’t seen the last of these proposals; they will be revived by the new […]
WHAT’S UP WITH THE DECEMBER 22 REGULATION Z CHANGES
On September 24, 2010 the Federal Reserve board issued an interim rule that requires new rate and payment disclosures in the “Fed Box.” The rule is effective on January 30, 2011. On December 22, 2010 the Fed issued an interim rule that modifies the September 24th interim rule. (An interim rule that modifies an interim rule; the Fed is starting to look like HUD.) The latest interim rule makes a couple of small changes to […]