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<p>WASHINGTON – CUNA’s Assistant General Counsel Jeffrey Bloch sent off a comment letter to the Federal Reserve Board at one time notifying the agency that it agrees with the Fed’s proposed revisions to Reg Z, Truth in Lending, as a way to ensure fairness for consumers in lending and also offering some additional suggestions of CUNA’s own. CUNA’s recommendation focused on a revised definition of “business day” for purposes of calculating rescission periods for certain home-secured loans. In its current form, “business day” is defined as all calendar days, except for Sundays and federal holidays. Federal law, Bloch noted, lists 10 federal holidays, but only four are identified by a specific date, such as July 3 for Independence Day. The remaining six holidays are identified by certain days of the week, such as “the third Monday in January.” In the Fed’s proposal, the language would be changed to clarify that for the four holidays identified by a specific date, only the date specified would be considered a legal holiday and not be included as part of the rescission period. Bloch cited by example, if July 4 fell on a Saturday, that government offices often celebrate the holiday on July 3. However, where it concerns rescission for certain home-secured loans, July 3 would be considered a ” business day,” not a holiday. Bloch said CUNA would support this approach “ only if the financial institution was open or otherwise available for business on the alternative date when the holiday itself falls on a weekend. If the institution were closed on this alternative date, the practical effect could be that the rescission period would essentially be shortened by one day, which would be unfair for consumers.” Concerning “requirements when disclosures appear on credit contracts,” Bloch wrote that CUNA supports the Fed’s clarification “because it represents a common sense approach when disclosures are placed on the same document as the credit contract.” The Fed’s proposal allows disclosures for closed-end loans to be placed on the same document with the credit contract, as long as they are “segregated from that contract.” In this type of situation, “the official staff commentary would clarify that lenders do not need to provide two separate copies to the consumer,” Bloch stated. “Instead of providing both an unsigned and then a signed copy, this requirement can be satisfied by giving the consumer one copy of an unexecuted credit contract, containing the disclosures, for him or her to read and then sign.” Bloch continued that, “This approach will also help to eliminate confusion that would result if both a blank copy and executed copy existed, which would be the case if lenders needed to create these two separate copies.” Lastly Bloch voiced no objection to the Fed’s proposed change permitting consumers the option to cancel credit insurance or debt cancellation coverage after consummation of the transaction, not after the initial payment. “Although these products have given rise to a number of consumer protection issues, we do not believe this change to the commentary will exacerbate these issues.,” he wrote. -</p> <p>[email protected]</p>

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