LOC Change in Term Disclosure Requirements

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August 29, 2013 at 10:17 am EDT #3907

Jody
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When notifying customers of a Unsecured LOC annual fee change, do we have any latitude in changing the format of G-21? Can the information be disclosed in a letter rather than the recommended tabular format?

Please and thank you.
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August 29, 2013 at 2:22 pm EDT #3913

rcooper
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The format requirements in 1026.9(c)(2)(IV)(D) state that the disclosure needs to be substantially similar to the model format. I don’t think a letter format would be substantially similar.

https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=c61f33bbcc880d96ad116f14b18d7b12&rgn=div5&view=text&node=12:8.0.2.9.18&idno=12
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