Yes, I've had 39 years experience with Reg. Z---and along the way I've gained a healthy respect for it's strange little twists, turns, and exceptions. One word--and certainly one definition--can change an answer totally.
JonD, your answer was right on the money and contained a cite. That's the way it's done & you shouldn't hesitate to challenge "experts" to defend their positions. That includes regulators. They get away with bulldozing bankers all the time because they're viewed as experts. With Reg. Z, sometimes there can be multiple correct answers or multiple paths to the best answer.
Randy, you've known me long enough to expect me to study a question twice before answering. I learned that the hard way, and those ABA Compliance Schools were one way I stayed sharp over the years. When you're surrounded by 300+ bankers and can't escape, you're going to be VERY embarrassed if you come up with wrong answers AND you get blasted with critical course evaluations after it's over. But..........as they say--no pain, no gain.
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...gone fishing.
He is probably one of the foremost authorities on Reg. Z in my mind. He has been top in my mind for the last twenty years after sitting as a wide-eyed beginning compliance officer at the ABA Compliance and Truth-in-Lendings Schools almost twenty years ago. But I guess that just makes me old......
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