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Reg M burdens should be minimized CUNA says
WASHINGTON (2/2/11)--A recent Federal Reserve proposal that would increase the threshold for Regulation M consumer lease disclosures to $50,000 is consistent with the new statutory requirement imposed by the Dodd-Frank Act, the Credit Union National Association (CUNA) has said in a Tuesday letter to the Fed. 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. Under the recent Dodd-Frank Act changes, the $50,000 threshold will come into effect on July 21. The amount of the applicable thresholds will be adjusted annually to reflect any increase in the Consumer Price Index. CUNA in its comment letter to the Fed said that the regulator should work to minimize the regulatory burdens associated with the proposal, particularly for small credit unions. CUNA has made similar requests related to proposed Regulation Z changes. (See related story: CUNA comments on Reg Z changes) One such burden is the requirement that lessors retain evidence of compliance for 24 months. CUNA urged the Fed to clarify which types of records must be maintained, and to remain mindful of the costs that regulated entities must bear to provide and maintain these records. The extra time needed to maintain and provide these records should also be noted by the Fed, and should be reduced, if possible, CUNA added. For the full comment letter, use the resource link.
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