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#1318156 - 01/05/10 08:26 PM Revised disclosures for private Education Loans
Soccer Offline
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Utopia
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
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#1318192 - 01/05/10 08:42 PM Re: Revised disclosures for private Education Loans Soccer
rlcarey Online
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Galveston, TX
Yes.
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#1318253 - 01/05/10 09:09 PM Re: Revised disclosures for private Education Loans rlcarey
Soccer Offline
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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
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#1318262 - 01/05/10 09:16 PM Re: Revised disclosures for private Education Loans Soccer
Skittles Offline
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TN
Yes, it applies. Took me by surprise, too.
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#1318352 - 01/05/10 10:18 PM Re: Revised disclosures for private Education Loans Skittles
rlcarey Online
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rlcarey
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Galveston, TX
It is going to take a lot of banks by surprise!
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#1319287 - 01/06/10 09:42 PM Re: Revised disclosures for private Education Loans rlcarey
OnTheEdge Offline
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SmallTown, USA
What's the mandatory compliance date?
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#1319312 - 01/06/10 09:53 PM Re: Revised disclosures for private Education Loans OnTheEdge
Skittles Offline
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TN
2/14/10
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#1320354 - 01/07/10 09:18 PM Re: Revised disclosures for private Education Loans Skittles
Cedar Point Guy Offline
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Cedar Point
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???
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#1320480 - 01/07/10 10:30 PM Re: Revised disclosures for private Education Loans Cedar Point Guy
rlcarey Online
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rlcarey
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Galveston, TX
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.
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