Disclosure Requirements for Open End Credit Under Regulation Z

Instructor: Stephen Bowe
Product ID: 703229
Training Level: Intermediate
  • Duration: 60 Min

recorded version

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This webinar highlights the practical aspects of complying with the disclosure requirements for open end credit including credit cards and home equity lines of credit (HELOCs). It will discuss the practical application of principles required to comply with the disclosures required for every step of the open end credit process including advertising, account opening, periodic statements and subsequent disclosures such as Change in Terms notices.

Why Should You Attend:

Although Regulation Z has been around for years the Credit Card Act of 2009 made significant changes specific to open-end credit. Additionally, with the advent of the Consumer Financial Protection Bureau (“CFPB”) and their emphasis on consumer protection, all prudential regulators are emphasizing transparency and clarity in a financial institution's consumer facing disclosures.

“Disclosure Requirements for Open End Credit under Regulation Z” is designed to be a practical ‘how-to’ workshop to review and tighten up your consumer facing disclosure documents. We will discuss in depth the disclosure requirements of those documents, including reviewing portions of the Commentary specific to those requirements. We will examine a credit card case study and put these Principles to the test.

Areas Covered in the Webinar:

  • General Disclosure requirements
  • Account Opening Disclosures
  • Periodic Statement Disclosures
  • Change In Terms Disclosures
  • Billing Error Resolution Communications
  • HELOC Specific Disclosures
    • Right of Rescission Notices
  • Advertising Disclosures
    • Print
    • Internet Based
    • Television & Radio

Who Will Benefit:

  • Compliance Officers
  • Regulatory Attorneys/In house Counsel
  • Risk Officers
  • Internal Auditors
  • Marketing Staff
  • Staff with roles and responsibilities in Compliance, Risk and Proofreading.

Instructor Profile:

Stephen J. Bowe, J.D., M.B.A., L.L.M. is a highly experienced and educated Financial Regulatory Compliance Attorney with extensive experience in drafting credit related documents including applications, terms and conditions, statements, change in terms and credit advertising disclosures, crafting policies and procedures, designing and implementing compliance and internal control testing programs, managing regulatory audits, and training on regulatory compliance related issues.

During his 15 years of experience, Mr. Bowe has been given the opportunity to work for companies ranging from small non-bank financial institutions, credit card issuers, consulting firms to large international financial institutions. His roles not only include legal and regulatory compliance but also operational risk management, internal audit, credit decisioning, marketing and executive management.

He is currently Senior Counsel & Director of Compliance for Universal Guardian Acceptance, LLC and owns and operates Compliance Navigator, a regulatory compliance consulting business and website for credit card issuers, banks and non-bank financial institutions.

Topic Background:

The Truth in Lending Act (“TILA”) was adopted and signed into law in 1968 to compel creditors extending credit to consumers to disclose the cost of the credit using a standardized format and terminology. The Act has been amended or expanded upon no less than 12 times since its original passage. Regulation Z was the implementing regulation promulgated by the Federal Reserve Board to administer the requirements of TILA.

Like TILA, Regulation Z is, at its heart, a regulation mandating meaningful disclosure. Its very purpose is to “promote the informed use of consumer credit by requiring disclosures about its terms and cost. “ Regulation Z has been amended recently and significantly with the passage of the Credit Card Accountability, Responsibility and Disclosures Act (“CARD”), the Mortgage Disclosure Improvement Act (“MDIA”) and the Dodd-Frank Wall Street and Consumer Protection Act (“Dodd-Frank”).

Specifically, the Dodd-Frank created the Consumer Financial Protection Bureau (“CFPB”) which removed the administration and rulemaking authority from the Federal Reserve Board and transferred that authority to the CFPB. The CFPB’s focus is strictly consumer protection and as such has placed a new emphasis on meaningful consumer disclosure. As a result, the CFPB, the FDIC, the OCC as well as State Attorneys General and the Fair Trade Commission are looking very closely at any financial institution’s consumer facing disclosures. This webinar reviews, in detail, the disclosure requirements of Regulation Z to help your financial institution maintain its compliance.

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