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Reg M Z comment deadlines near
WASHINGTON (1/28/11)--The Credit Union National Association (CUNA) has issued a regulatory comment call on the Federal Reserve Board’s proposal that would increase the threshold for Regulation Z consumer credit disclosures to $50,000. Consumer credit transactions of up to $25,000 are currently subject to several disclosure requirements under the Truth in Lending Act (TILA) and Regulation Z. Private education loans and loans secured by real property, such as mortgages, are subject to TILA regardless of the amount of the loan. Regulation Z implements the Home Ownership and Equity Protection Act (HOEPA) by adjusting the thresholds used to determine which loans are covered under HOEPA. A separate but similar Fed proposal would increase the threshold for Regulation M consumer lease disclosures to $50,000. Regulation M generally applies to consumer leases for the use of personal property, such as automobiles, where the contractual obligation has a term of more than four months. All of the above regulatory changes will come into effect on July 21, and the amount of the applicable thresholds will be adjusted annually to reflect any increase in the Consumer Price Index. Comments are due to CUNA by Jan. 31. Comments solicited by the NCUA should be submitted by Feb. 1. To view the CUNA comment calls, use the links.


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