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CFPB Reg E Disclosure Requirement

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Question: 
Prior to transfer to CFPB Reg E disclosure requirement under 205.3(b)(2)(iii) retired on 12/31/2009. However, CFPB Reg E 1005.3(b)(2)(iii) does not mention the disclosure is no longer required as of Dec 2009. Does this mean the CFPB has re implemented this disclosure requirement?
Answer: 

If you take a look at the old version of 205.3(b)(2) in BOL's Alphabet Soup you'll see that paragraph 205.3(b)(2)(iii) appears in gray to reflect the fact that it expired at the end of 2009. There's also a paragraph (iv) that follows, which refers to use of Model Clause A-6.

In the CFPB regulation, 1005.3(b)(2) does not include the outdated paragraph (iii). It renumbered old paragraph (iv) as paragraph (iii).

Incidentally, the CFPB regulation still includes Model Clause A-6(c), which used to be used to comply with the expired requirement.

First published on BankersOnline.com 7/2/12.

First published on 07/02/2012

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