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#208657 - 07/08/04 12:44 PM Reg Z Exemption
Expedition Offline
Member
Joined: May 2002
Posts: 54
In 1996 a new subsection was added to TILA 105(g) giving the Board authority to exempt credit transaction of consumers with $200k income or net assets 1M and the consumer signs a waiver. Did the Fed ever promulgate this section of the Act? If they didn't, can I assume you cannot use this exemption unless the Fed amends Reg Z? I've checked Reg Z and cannot find any such exemption. As I recall from my earlier days with Reg Z you could not exempt such transactions but I just wanted to make certain that is still true

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Lending Compliance
#208658 - 07/08/04 04:22 PM Re: Reg Z Exemption
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I'll bite. Hmmm, I've never heard of a Reg Z amendment for this. Therefore, I'll also assume that you cannot use this exemption.

Richard?
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#208659 - 07/08/04 04:34 PM Re: Reg Z Exemption
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
I'm not Richard, but I would think that since that section of the law only gives the Fed Board the authority to exempt loans to a certain group of consumers from the requirements of the reg, the exemption doesn't exist unless and until the Fed Board chooses to amend Reg Z.
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#208660 - 07/08/04 04:37 PM Re: Reg Z Exemption
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
I'm like David, I have never heard of this before, but it is definitely in the Act. However, I also agree with Deena's assessment.
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