Reporting, Recordkeeping and Disclosure Requirements in Connection with Regulation Z (Truth in Lending) and Section 227.28 of Regulation AA (Unfair or Deceptive Acts or Practices (UDAP))
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Reporting, Recordkeeping and Disclosure Requirements in Connection with Regulation Z (Truth in Lending) and Section 227.28 of Regulation AA (Unfair or Deceptive Acts or Practices (UDAP))
TILA and Regulation Z ensure adequate disclosure of the costs and terms of credit to consumers. For open-end credit, creditors are required to disclose information about the initial costs and terms and to provide periodic statements of account activity, notices of changes-in-terms, and statements of rights concerning billing error procedures. The regulation also requires specific types of disclosures for credit and charge card accounts, and home-equity plans. For closed-end loans, such as mortgage and installment loans, cost disclosures are required to be provided prior to consummation. Special disclosures are required of certain products, such as reverse mortgages, certain variable-rate loans, and certain mortgages with rates and fees above specified thresholds. TILA and Regulation Z also contain rules concerning credit advertising.
PL: Pub.L. 111 - 24 123 Stat. 1734 Name of Law: Credit Card Accountability Responsisbility Act of 2009
PL: Pub.L. 111 - 22 123 Stat. 1632 Section 404(a) Name of Law: Helping Families Save Their Homes Act of 2009
PL: Pub.L. 110 - 315 1021-1022 Name of Law: Higher Education Opportunity Act (HEOA) of 2008
PL: Pub.L. 111 - 203 1100E, 124 Stat 1376 Name of Law: Dodd-Frank Act
On December 16, 2010, a notice of proposed rulemaking (NPRM) was published in the Federal Register (75 FR 78636) requesting public comment on the proposed amendments to Regulation Z. The proposed amendments implement Section 1100E of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), which was signed into law on July 21, 2010. The Dodd-Frank Act raises TILA's $25,000 exemption threshold to $50,000, effective July 21, 2011. In addition, the Dodd-Frank Act requires that, on or after December 31, 2011, the threshold shall be adjusted annually for inflation by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPIÂW), as published by the Bureau of Labor Statistics. Beginning on January 1, 2012, the $50,000 threshold will be adjusted annually based on any annual percentage increase in the CPIÂW. The Federal Reserve is proposing to amend Section 226.3(b) and the accompanying commentary for consistency with the amendments to TILA's exemption threshold. The comment period for this NPRM expired February 14, 2011. The Federal Reserve received 10 comment letters; however, none specifically addressed the paperwork burden. On April 4, 2011, a notice of final rulemaking was published in the Federal Register (76 FR 18354) adopting the amendments largely as proposed, with mandatory compliance by July 21, 2011.
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