ICBA - Publications - Fed Updates Reg Z

Fed Updates Reg Z

WWR Article - April 30, 2004

The Federal Reserve has revised several provisions of Regulation Z (Truth-in-Lending). The first change clarifies that disclosure of an amount must be a numerical figure. Second, if a consumer rescinds a loan, sending a rescission notice to the address where payments are sent is sufficient if the lender did not provide an address for rescission notices. The changes also clarify that a court order can alter the sequence of events for rescission without undermining the consumer's right to rescind.

The Fed declined to adopt proposed changes to the Reg Z definition of "clear and conspicuous" disclosures. The Fed had considered applying the current definition of clear and conspicuous from the privacy rule to several other consumer protection rules, including Reg Z. ICBA and others raised serious concerns about the potential burden and confusion from the proposal. The Fed has decided not to make any changes to Reg Z in this regard and is continuing to study the matter.

The Fed also announced it continues to study disclosures for debt cancellation and debt suspension agreements and whether those disclosures should be included in the calculation of the APR. Additional information is available at www.federalreserve.gov.