Reg Z Flashcards
What types of credit products are covered under Reg Z?
All consumer loans
What types of credit products are excluded?
Business, commercial and agricultural
Loans made to non-natural persons
Reg Z covers both open-end and closed-end credit.
What are the definitions of each?
Open-end:
repeated transactions,
finance charge on the outstanding balance,
amount of available credit is replenished as the outstanding balance is repaid
Closed-end:
term specific
What is a ‘dwelling’?
Residential structure that contains 1to 4 units, whether or not that structure is attached to real property.
Including condos, coops, mobile homes and trailer, if used as a residence
Are there differences in the account opening disclosures for HELOCs and other open-end credit?
When must the disclosures be provided?
Account opening disclosures must be provided to the member prior to the first transaction being conducted.
Yes HELOC disclosures are different than other open-end credit disclosures because they are disclosures at the time of application.
What disclosures are required when advertising a promotional APR?
When the promotional rate will end and;
The APR that will apply after the end of the promotional period
What are the change-in-terms requirements for open-end credit?
Are the rules the same for all open-end products?
If not, what are the differences?
45 day advanced notice of a change in terms
Can be included in the periodic statement or in a separate mailing
Tabular format
Specific content requirements
*special cases for APR increases
*right to reject
*delinquency
No, this does not apply to HELOCs
What are the periodic statement requirements for the different open-end credit products?
What are the timing requirements for providing each statement?
Required for each billing cycle
Must group fees and interest charges separately from other transactions
Fees and interest must be totaled for the period (ie monthly) and Year to Date
Disclosed in a tabular format
Must be mailed at least 21 days prior to the member’s due date
Late payment warning
Minimum payment warning
Repayment disclosure example
When are additional disclosures required for open-end credit advertising?
Are there any exceptions?
Whenever there is a trigger term:
APR
Transaction fees
Annual fee
Any minimum, fixed, transaction, activity or similar charge that is a finance charge
APR and if the plan provides for a variable APR
Any membership or participation fee that could be imposed
Yes, there are exceptions for tv and radio advertisements. CU provide the APR and a toll free phone#
What are the special rules applicable to HELOCs?
prohibited from:
changing terms,
terminating plans
demanding repayment
Do all open-end credit products have application disclosure requirements?
If not, which ones do?
No, credit card accounts and HELOCs, disclosures are also required during the application process.
What are the special advertising rules applicable to HELOCs?
Must include:
Discount or Premium Initial Rates
Balloon Payments
Tax Implications
Promotional Rates and Payments
