I have searched "JWNDAA" on BOL, have read both BOL articles by Andy Zavoina, Mary Beth Hurt and John Burnett, and have read/re-read the proposed regulation and I still have the subject Question.

The definition for Consumer Credit says it means the following transactions: Payday loans, vehicle title loans and tax refund loans.

Creditor means "...extending consumer credit with respect to a consumer credit transaction covered by this part." Again, the three "loans" above,.

Covered Borrower means "....becomes obligated on a consumer credit transaction covered by this part." Again, the three "loans" above.

We don't make payday loans, car title loans or RALs, so
if my FDIC-regulated Bank is making a $1,000 unsecured loan to an Army Sgt to take a vacation, where does JWNDAA say THIS is a covered consumer credit transaction ? I'm really quite confused on this issue. It all seems to be tied around the phrase "...covered by this part."

I was on vacation last week and didn't get to your post until today.

The huge unknown factor here is IF the implementing regulation will even include regulated lenders such as banks. It may not, making this moot for most of us. Both "consumer credit" and "creditor" will be defined terms, or should be. Otherwise, here is a clip from my Dec. 2006 Executive Briefing:

This new law applies to all consumer loans, except home mortgages and loans for the purchase of "a car or other personal property," if secured by the property purchased. It applies to loans done in a branch, through the mail or over the internet.

Here is the definition from the law:
`(6) CONSUMER CREDIT- The term `consumer credit' has the meaning provided for such term in regulations prescribed under this section, except that such term does not include (A) a residential mortgage, or (B) a loan procured in the course of purchasing a car or other personal property, when that loan is offered for the express purpose of financing the purchase and is secured by the car or personal property procured.'.

Thank you for your advice and reply. I couldn't find a date on the printed BOL briefings to determine if they were based on the statute or also took the proposed rulemaking into consideration.

I didn't want to write, "The Chicken Little Papers - The Sky is Falling", if it wasn't.....and I now know is probably won't.

Hope you had a great vacation......and, again, your guidance is most appreciated.