Recordkeeping and Disclosure Requirements Associated with CFPB’s Regulation Z

The Truth in Lending Act (TILA) and Regulation Z ensure adequate disclosure of the costs and terms of credit to consumers. For open-end credit, such as credit cards and home-equity lines of credit (HELOCs), creditors are required to disclose information about the initial costs and terms and to provide periodic statements of account activity, notices of changes in terms, and statements of rights concerning billing error procedures. For closed-end loans, such as mortgage and installment loans, cost disclosures are required prior to and at consummation. Special disclosures are required for certain products, such as reverse mortgages and high cost mortgages with rates and fees above specified thresholds. TILA and Regulation Z also contain rules concerning credit advertising. Creditors are required to comply with Regulation Z’s disclosure and other requirements unless the transaction is exempt. Regulation Z generally does not apply to consumer credit transactions that exceed a threshold amount, adjusted annually for inflation. However, regardless of the amount of credit extended, Regulation Z applies to (1) consumer credit secured by real property, (2) consumer credit secured by personal property used or expected to be used as the principal swelling of the consumer, and (3) private student loans. On July 21, 2011, rulemaking authority for TILA was transferred from the Board to the CFPB under the Dodd-Frank Act. In December 2011, the CFPB published an interim final rule establishing its own Regulation Z to implement TILA at 12 C.F.R. part 1026 that substantially duplicated the Federal Reserve’s Regulation Z. The CFPB has subsequently amended its Regulation Z to adopt rules required by the Dodd-Frank Act.

The latest form for Recordkeeping and Disclosure Requirements Associated with CFPB’s Regulation Z expires 2021-05-31 and can be found here.

Open-End (Not Home-Secured) Credit: Applications and solicitations (Section 1026.60)

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