The Truth In Lending Act and Regulation Z have traditionally had a single disclosure for all closed-end transactions. Starting in 2015 separate discloses were required for closed-end transactions secured by real property (TRID). Closed-end transaction s that are unsecured or secured by property other than real property are still disclosed using the "fed box" disclosure required by §1026.18.
Over the last five years financial institutions have invested huge amounts of time and money on the implementation of TRID, but through that entire period examiners were zeroed in on the old "fed box" disclosure, particularly the APR and finance charge disclosures. Even today lenders are frequently surprised when violations of these older rules are cited.
This two-hour program provides a comprehensive review of the disclosure rules for closed-end credit transaction that are not secured by real property. Whether you are new to this section of Regulation Z or a veteran seeking a review of the requirements, this program will meet your needs. Don't be surprised when examiners dredge up violations from this older section of Regulation Z
- Which transactions are covered by or exempt from Regulation Z;
- The differences between open-end and closed-end credit.
- What transactions are required to receive a "fed box" disclosure;
- The general disclosure rules under §1026.17, including the timing rules for delivery of the disclosures;
- The 20 disclosures required by §1026.18 that appear in the "fed box" disclosure, including the:
- Amount Financed,
- Finance Charge;
- Annual Percentage Rate;
- Payment Schedule, and the Interest and Payment Summary;
- Total of Payments;
- Insurance and Debt Cancellation; and
- Security Interest
Who Should Attend?
The program is designed for loan officers, compliance officers, loan support staff, marketing staff, auditors, and any others with responsibilities related to the origination of closed-end credit.
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