CFPB Proposes Amendments to "Truth in Lending" Regulations Concerning Discontinuation of LIBOR

The CFPB proposed amendments to Truth in Lending regulations ("Regulation Z") that address issues concerning the discontinuation of LIBOR.

The proposal would "facilitate creditors’ transition away from using LIBOR as an index for variable-rate consumer credit products." In addition, the CFPB is requiring certain notice requirements concerning credit card rate reevaluation requirements. Comments on the proposal are due by August 4, 2020.

The Bureau also issued a question-and-answer document concerning compliance with CFPB regulations that would be impacted by the LIBOR transition.

Further, the CFPB updated its Consumer Handbook on Adjustable Rate Mortgages ("CHARM"). CHARM is required to be distributed by lenders within three days after an adjustable-rate mortgage application.