Bank Policy Institute
CFPBRulemakingCFPB-2020-0014

Facilitating the LIBOR Transition (Regulation Z)

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Jun 20, 2024
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closed 2184d ago
Bank Policy Institute filings
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Bank Policy Institute filed 1 comment on this docket between Aug 4, 2020 and Aug 4, 2020. 3 other organizations filed here. The comment window closed 2184d ago.

What Bank Policy Institute filed (1)

Aug 4, 2020· Comment Submitted by Naeha Prakash, Bank Policy Institute· CFPB-2020-0014-0016

Please see attached a comment from the Bank Policy Institute.

Abstract

The Bureau of Consumer Financial Protection (Bureau) is proposing to amend Regulation Z, which implements the Truth in Lending Act (TILA), generally to address the sunset of LIBOR, which is expected to be discontinued after 2021. Some creditors currently use LIBOR as an index for calculating rates for open-end and closed-end products. The Bureau is proposing changes to open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. The Bureau also is proposing to permit creditors for home equity lines of credit (HELOCs) and card issuers for credit card accounts to transition existing accounts that use a LIBOR index to a replacement index on or after March 15, 2021, if certain conditions are met. The proposal also addresses change-in-terms notice provisions for HELOCs and credit card accounts and how they apply to accounts transitioning away from using a LIBOR index. Lastly, the Bureau is proposing to address how the rate reevaluation provisions applicable to credit card accounts apply to the transition from using a LIBOR index to a replacement index.

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Facilitating the LIBOR Transition (Regulation Z) (CFPB) — Bank Policy Institute | OpenPolis