Does anyone have clarification of this new Reg Z requirement? I understand that this does not include Govt back loans. However if a customer enters a branch and applies for an unsecured loan and states that it is for secondary education expenses does that tigger the need for further disclosures?
Thanks

Yes.

Just one more quick question. Even if we don't offer an Education Loan product this still applies? We are looking at personal credit consumer application where customer has stated purpose ie: books, tuition.
Thanks again

Yes, it applies. Took me by surprise, too.

It is going to take a lot of banks by surprise!

What's the mandatory compliance date?

2/14/10

Hi all,

What if we have a loan for secondary education loans (that meet the rule) and it needs to be renewed after the mandatory compliance date? Would we have to do the new disclosures or would it be grandfathered in? I have looked every where but can not find the answer in the reg. We have made the decision not to do these types of loans as we are a small bank and do not have any other options for the customer. Any thoughts???

You would have to look at 226.20 to see if it was a refinance or not. If it is a refinance - then you would have to provide the disclosures.