Reg Z Policy Template Update Details

What's New

Topic 10 - Open End Credit - Requirements for Home Equity Plans. The following former topics were combined into one new topic to mirror regulatory guidance:

Home Equity Lines - Early Disclosure Statement Requirements - Formerly Topic 20

Limitations on Home Equity Plans - Formerly Topic 21

Topic 19 - Open End Credit - Determination of Annual Percentage Rate. Portions of this new topic were formally included within Topic 10 - Rules of Annual Percentage Rate, to mirror regulatory guidance specific to open end credit.

Topic 20 - Open End Credit - Right of Rescission. Portions of this new topic were formally included within Topic 30 - Right of Rescission, to mirror regulatory guidance specific to open end credit.

Topic 21 - Open End Credit - Advertising. Portions of this new topic were formally included within Topic 31 - Advertising, to mirror regulatory guidance specific to open end credit.

Topic 24 - Closed End Credit - Certain Residential Mortgage and Variable Rate Transactions. The following former topics were combined into one new topic to mirror regulatory guidance:

Certain Residential Mortgage Transactions - Topic 26

Certain Variable Rate Transactions - Topic 27

Topic 27 - Closed End Credit - Determination of Annual Percentage Rate. Portions of this new topic were formally included within Topic 10 - Rules of Annual Percentage Rate, to mirror regulatory guidance specific to closed end credit.

Topic 28 - Closed End Credit - Right of Rescission. Portions of this new topic were formally included within Topic 30 - Right of Rescission, to mirror regulatory guidance specific to closed end credit.

Topic 29 - Closed End Credit - Advertising. Portions of this new topic were formally included within Topic 31 - Advertising, to mirror regulatory guidance specific to closed end credit.

Topic 31 - Audit Policy. This topic provides guidance with respect to a financial institution's requirement to conduct periodic independent audit reviews of its consumer lending compliance activities.

What's Revised

Topic 2 - Policy Statement. The following former topics were added to the "General" subtopic:

Truth In Lending Background - Formerly Topic 5

Coverage - Formerly Topic 7

Topic 8 - Open End Credit - General Disclosure Requirements. The first two paragraphs of the "Form of Disclosures" subtopic were revised. In addition, the subtopic "Electronic Communication Rules" was deleted.

Topic 9 - Open End Credit - Credit and Charge Card Applications and Solicitations. The two paragraphs prior to bullet point 3. under the "General" subtopic were revised.

Topic 22 - Closed End Credit - General Disclosure Requirements. The following subtopics were revised:

Form of Disclosures

Time of Disclosures

Early Disclosures

In addition, the following subtopics were added to expand regulatory guidance:

Mail or Telephone Orders - Delay in Disclosures

Series of Sales - Delay in Disclosures

Interim Student Extensions

Language of Disclosures

Topic 25 - Closed End Credit - Subsequent Disclosure Requirements. The following subtopics were revised to include additional detail:

Refinancing

Assumptions

Variable Rate Adjustments

Topic 26 - Closed End Credit - Treatment of Credit Balances. The "General" subtopic was revised.

Topic 30 - Special Rules for Certain Home Mortgage Transactions. The former Topic 32 - Reverse Mortgages is now included as a subtopic.

Topic 33 - Retention of Documentation. This topic was revised to mirror current regulatory guidance.

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