What is the notification requirement when changing an account term that requires disclosure under Reg Z?

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When changing an account term that requires disclosure under Regulation Z (Reg Z), the correct procedure involves mailing a written notice to the member at least 45 days prior to the effective date of the change. This requirement is rooted in the Truth in Lending Act, which Reg Z enforces, aimed at ensuring that consumers receive timely and clear information about changes to the terms of their credit accounts.

The 45-day notice period allows consumers to understand the implications of the change and, if they wish, to adjust their financial decisions accordingly. For example, if there is an increase in fees or changes in interest rates, this advance notification gives the consumer the opportunity to consider their options, including the possibility of choosing a different financial product if the new terms do not meet their needs.

Other options do not align with the regulatory requirements outlined in Reg Z. For instance, notifying the member 30 days before the change does not meet the regulatory standard, as the notice must be at least 45 days prior to the effective date. Similarly, notifying immediately after a change does not provide the consumer with the necessary advance information, undermining the intent of consumer protection. Lastly, stating that no notification is required contradicts Reg Z's mandate for transparency and consumer awareness regarding credit terms

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