Loan is secured by a CD and a vehicle. Wouldn't the CD as collateral trigger the Required Deposit disclosure? Generally, we don't have both a CD and vehicle as collateral, but it is that way on this particular loan and has no Required Deposit disclosure. Thanks.

Yes - needed.

Randy's answer is correct in 2017, but Reg. Z's concept of a "required deposit" has changed over the years. In the wonderful world of regulations, nothing is ever forgotten totally, so (like me) some of you might argue that this disclosure shouldn't include pre-existing CDs and other deposit accounts that are subsequently offered as collateral.

Before "simplification" in 1981, you would have been right. From my March 1977 copy of "old Reg. Z": "The following amounts shall be disclosed...any deposit balance...except a deposit balance or investment which was in existence prior to the extension of credit and which is offered by the customer as security for that extension of credit...."

Post-simplification, we would be wrong. Regardless of the history of the deposit, if the credit agreement calls for its ongoing existence, Section 1026.18(r) requires a disclosure that there is a "required deposit".

I love it when Grandpa Richard digs out the history books and blows the dust off of them! It's enlightening!

I expected a Geritol comment of two & that's OK.

My purpose was to provide a definitive answer to one of those questions on old topics (like old Reg. Q) that pop up from time to time. Someone remembers how they did it 3 employers and 5 jobs ago & needs to be convinced that the old rules went away and that different rules (or none at all) apply today.

I meant no disrespect. In fact, I love your definitive answers and history lessons. I'm 51 now and have been doing compliance since 1990. I have quite a few examples of old topics and how regs have evolved myself. I very much appreciate you!