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#1430064 - 08/17/10 03:53 PM Regulation Z and charge off accounts
tickledpink Offline
Junior Member
Joined: Feb 2006
Posts: 37
I'm trying to determine if the new periodic statement changes of Regulation Z applies to charge off accounts. Here is the scenario:

We have accounts charged off and off our books. A customer comes back to us and initiates a repayment plan. Do we need to starting sending statements compliant with the new Reg. Z requirements. Or does the regulation no longer apply because the account is off our books?

Can anyone give me some insight on this issue? I'm able to find anything that truly addresses the issue.

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Lending Compliance
#1430074 - 08/17/10 04:00 PM Re: Regulation Z and charge off accounts tickledpink
tickledpink Offline
Junior Member
Joined: Feb 2006
Posts: 37
I should clarify "open-end" accounts

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#1430587 - 08/18/10 01:55 PM Re: Regulation Z and charge off accounts tickledpink
ComplianceJoe Offline
New Poster
Joined: May 2010
Posts: 10
Under Reg. Z Section 226.5(b)(2)(i) a periodic statement does not have to be sent to an account holder if the creditor deems it uncollectible - or if collection proceedings have been instituted - or if the account has been charged off and interest and fees are not being charged in accordance with the loan loss reserve provision.
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#1430984 - 08/18/10 07:51 PM Re: Regulation Z and charge off accounts ComplianceJoe
tickledpink Offline
Junior Member
Joined: Feb 2006
Posts: 37
But what if the consumer comes back after charge off and initiates a repayment plan. Interest is now being charged again, but the account is no longer on our books. Do we have to send out a statement compliant to the new rules under Reg. Z? Or is Reg. Z null and void since it's no longer on our books?

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