Does the Higher Education Opportunity Act and its disclosures, cover a consumer, unsecured loan, for educational expenses to an undergraduate school?
If we give a loan to someone to consolidate their existing student loans, are the private education loan new disclosures required? They are no longer in school, just refinancing the debt.
Our software only supports 2 of the 3 required disclosures for private education loans. They claim that if you approve the loan within 3 days of receiving the application, that you are not required to give the customer the "application" disclosure, only the approval and final disclosures. Is this true or do I need to find the other disclosure somewhere else?
Can a bank secure a private education loan with a closed end loan secured by real property or principal dwelling? I have read the reg and I see where is says “loans not covered.” What does “not covered” mean?
Is there a three day wait period between the time a private education loan is disclosed and the closing date according to Regulation Z, or can the borrower close at any time after receiving the disclosures?
Concerning the new disclosures for private education loans, we do not have a special type set up for these loans, but we do make loans to consumers, and the purpose that is given is for education purposes. Does the new Reg.Z requirement for the additional disclosures apply to these loans? I have been told that if we do not have a loan type that is specific for the education loans, we would not need to do the disclosures, but in what I read, it refers only to the purpose as being the trigger for the new disclosures. Can you clarify this for me?