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December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
Sam Ott

December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 11, 2014
Setting up New Accounts for Trusts
Mary Beth Guard

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



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

Registered: 05/08/07
Posts: 763
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 Online
100 Club

Registered: 01/25/08
Posts: 241
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: 50718
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 Online
100 Club

Registered: 01/25/08
Posts: 241
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: 50718
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 Online
100 Club

Registered: 01/25/08
Posts: 241
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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