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Acting As Seller of Repossessed Automobile

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Question: 
Are additional disclosures required if a lending institution elects to act as the seller of a repossessed automobile?
Answer: 

At a minimum, you must provide the "credit sale" disclosures required by Section 1026.18(j) of Regulation Z.

[Editor's Note: There are also state law issues that may require additional disclosures by such a seller. For example, there may be UCC Article 9 notice requirements. We advise lenders who occasionally act as sellers of repossessed collateral of all types be familiar with not only federal, but also state requirements involved. Check with an attorney familiar with local laws before venturing into what may be unfamiliar territory.]First published on BankersOnline.com 6/10/13

First published on 06/10/2013

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