Thread Options
#2066584 - 02/29/16 05:46 PM Repeal of Reg AA
Ninky Offline
Gold Star
Ninky
Joined: Nov 2002
Posts: 357
With the official repeal of Reg AA, are we no longer required to provide the Co-signer notice at closing? Even though repealed, I still see value in providing the notice from a UDAAP standpoint. Any harm in continuing the practice? Don't see a downside.

Return to Top
Lending Compliance
#2066605 - 02/29/16 06:17 PM Re: Repeal of Reg AA Ninky
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,710
Bloomington, IN
Click here . The Fed is also proposing to repeal Reg. C.

As Waldensouth stated these repeals are a result of the regulations no longer falling under the Fed's rule making authority.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2067096 - 03/02/16 05:25 PM Re: Repeal of Reg AA Ninky
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
In the Interagency Guidance Regarding Unfair or Deceptive Credit Practices that the agencies issued in August of 2014 they signaled their views on the Cosigner Notice in footnote 11, which said:

“The Agencies note that the FTC’s Credit Practices Rule requires—and the former credit practices rules applicable to banks, savings associations, and Federal credit unions required—creditors to provide a “Notice to Cosigner” explaining the cosigner’s obligations and his or her liability if the borrower fails to pay. The Agencies believe that creditors have properly disclosed a cosigner’s liability if, prior to obligation, they continue to provide a “Notice to Cosigner.”

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20140822a2.pdf

Return to Top

Moderator:  Andy_Z