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For more than 25 years, credit unions have used multi-featured, open-end lending as their preferred method to make non-real estate, secured consumer loans. Approximately half of all credit unions use this lending approach, and about 60% of credit unions with assets of more than $100 million use multi-featured, open-end lending as their primary method of meeting members’ demands for loans.

However, recently proposed changes to Regulation Z–the implementing regulation for the Federal Truth in Lending Act (TILA) governing consumer credit disclosures–by Federal Reserve Board staff would put credit unions’ use of open-end lending in jeopardy.

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