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CUNA CUNA Mutual join in Reg Z comment drive
WASHINGTON (10/25/10)--The Credit Union National Association (CUNA) is working closely with CUNA Mutual to raise awareness of the negative aspects of the Federal Reserve’s proposed disclosures that would be required for credit insurance and debt cancellation and suspension products. CUNA and CUNA Mutual, through a grassroots operation called “Operation Comment,” are encouraging credit unions to report their concerns with the proposals to the Fed. Credit unions should also address how these proposed disclosures will discourage consumers from purchasing payment protection products. Jeff Bloch, CUNA senior assistant general counsel, said that activating CUNA's Operation Comment at this time “is one important part” of the Fed-centered response, which CUNA has successfully used in the past for other problematic regulatory proposals.” These new disclosures for credit insurance and debt cancellation and suspension products are misleading and would likely discourage consumers from purchasing those products. These disclosures are being proposed in addition to other consumer protections and mortgage loan disclosures. These will change the rescission provisions and will change the disclosures and other requirements for reverse mortgage loans. The proposal also seeks to ensure that borrowers are supplied with new disclosures when the key terms of a closed-end mortgage loan are modified. CUNA has said that the disclosures “go well beyond ensuring that consumers are informed about these products,” instead casting the products “in a strictly negative light” and strongly discouraging the purchase of the products. For CUNA’s comment call, use the resource link.
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