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January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



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#1415172 - 07/15/10 12:21 AM REG Z - Education Loans
banker-12 Online
Platinum Poster

Registered: 05/08/07
Posts: 768
If we closed a loan prior to the new private education loan rules and the purpose was to pay-off a student loan at another FI, is it considered a PEL if we renew it today? I believe it is because we will be refinancing a loan org. to pay-off a student loan, but I want to be sure.

thanks,

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Lending Compliance
#1426407 - 08/10/10 09:38 AM Re: REG Z - Education Loans [Re: banker-12]
illiniyak Offline
100 Club

Registered: 01/25/08
Posts: 243
Bump

If it's a renewal (no new money) do we need to do PEL disclosures?

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#1426492 - 08/10/10 10:54 AM Re: REG Z - Education Loans [Re: illiniyak]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 51223
Loc: Galveston, TX
Yes.In reviewing the final student loan regulations released by the Federal Reserve on August 14, 2009, the following is found in the discussion within the preamble to the regulations.



“The final rules require a complete disclosure at the time the credit is extended. In addition, new disclosures are required under § 226.20(a) in the case of a refinancing of a loan.”



So, unfortunately, the refinancing of any current loan will fall under all the new student loan requirements, which will include the application disclosures, the pre-closing disclosures and the final disclosures at loan closing along with the right of rescission.


_________________________
The opinions expressed are my own, take them or leave them.

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#1426714 - 08/10/10 01:38 PM Re: REG Z - Education Loans [Re: rlcarey]
illiniyak Offline
100 Club

Registered: 01/25/08
Posts: 243
If it isn't a new note (it's only an extension of the current terms) you still have to do the disclosures?

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#1426772 - 08/10/10 02:26 PM Re: REG Z - Education Loans [Re: illiniyak]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 51223
Loc: Galveston, TX
You would have to look at 226.20 to determine whether it is a refinance or not. No refinance - no new disclosures, regardless of the subsection of Reg. Z the loan would fall under.
_________________________
The opinions expressed are my own, take them or leave them.

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#1426785 - 08/10/10 02:33 PM Re: REG Z - Education Loans [Re: rlcarey]
illiniyak Offline
100 Club

Registered: 01/25/08
Posts: 243
Thank you

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#1498813 - 01/21/11 03:54 PM Re: REG Z - Education Loans [Re: rlcarey]
Valley Girl Offline
100 Club

Registered: 02/12/08
Posts: 142
Originally Posted By: rlcarey

So, unfortunately, the refinancing of any current loan will fall under all the new student loan requirements, which will include the application disclosures, the pre-closing disclosures and the final disclosures at loan closing along with the right of rescission.


The bank made some education loans prior to Feb. 14, 2010 which are now maturing. The customer would like to consolidate these "student loans" into one loan. So it sounds like the application disclosure must be given with a consolidation loan. I'm a little confused as to how to complete the Loan Cost Examples which state under Repayment Option, "while enrolled in school."

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