Repeal of Reg AA

Posted By: Ninky

Repeal of Reg AA - 02/29/16 05:46 PM

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 Even though repealed, I still see value in providing the notice from a UDAAP standpoint.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.
Posted By: Dan Persfull

Re: Repeal of Reg AA - 02/29/16 06:17 PM

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.
Posted By: Ted Dreyer

Re: Repeal of Reg AA - 03/02/16 05:25 PM

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