By: ABIA Outside Counsel Chrys D. Lemon and Adam D. Maarec, McIntyre & Lemon, PLLC
The sale of debt protection products by banks is governed by rules issued by the Federal Reserve Board (FRB) and the Office of the Comptroller of the Currency (OCC). Both regulatory regimes are based on disclosing material terms to consumers and obtaining their informed consent to purchase the product. Revised regulations proposed by the FRB would significantly reshape how the products are regulated under Regulation Z, especially with regard to required disclosures. But the fate of those regulations, which were transferred to the Consumer Financial Protection Bureau (CFPB), is unclear.
Read a review of current debt protection regulations and an update on the status of these proposed revisions.
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