A Comprehensive Guide to Reg Z: Closed-End Credit Compliance
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Gain a practical understanding of Regulation Z and how to avoid common pitfalls.
The Truth in Lending Act's implementing rule, Regulation Z, attempts to protect consumers by requiring lenders to facilitate an informed credit decision by providing detailed disclosures at various points during the life cycle of the loan. Many lenders and their employees find Regulation Z's substantive and timing requirements to be confusing and unclear, but they do not have the time to consult with an attorney or compliance officer every time a loan term or other fact changes. This topic helps lenders and loan officers avoid the potentially significant penalties and sanctions associated with violating Regulation Z by helping them understand when the rule applies, as well as how to maintain compliance in areas of advertising, APR calculations, disclosures, and more.
AuthorsPavitra (Pavy) Bacon, Ballard Spahr LLP
Is My Loan Covered by Reg Z?
• Covered Transactions
• Certain Mortgage Transactions - High-Cost Mortgages, Higher Priced Mortgages and Qualified Mortgages
Selling the Loan: Advertising
• General Requirements
• Trigger Terms
• Media Requirements
Making the Loan: What's the APR?
• Fees and Finance Charges
• APR vs. Interest Rate
• APR Calculations
Making the Loan: What Do I Need to Tell the Customer?
• Disclosure Requirements
- General Requirements
- Oral Disclosures
- NonEnglish Disclosures
• Content and Timing Requirements
• Certain Mortgage and Variable-Rate Disclosure Requirements
The Loan's Closed: Now What?
• Post-Closing Disclosure Requirements
• Right of Rescission
• Record Retention
• State Law Considerations