The scope of Reg. Z’s student loan rule

Hi compliance folks! My name is Loran, and I am the newest edition to your favorite team, the NAFCU regulatory compliance team! It is only right, as the millennial that I am, to kick off my first blog with a topic that haunts my dreams… student loans… private education loans, to be exact.

Sections 1026.46-48 of Reg. Z impose requirements on lenders for private education loans, including disclosure of terms and interest rates. It also imposes requirements on lenders regarding advertisement of these terms. As explained in the CFPB Education Loan Servicing Exam Manual, the requirements of this section apply to “private education loans” and any lender who offers them (looking at you, credit unions).

Who is a private education lender?

Any creditor who makes a “private education loan,” is a private education lender. A private education lender may be a credit union, bank, and even the educational institution the borrower attends. Reg. Z does not put limitation on who is regulated by this section, but focuses on what is regulated: private education loans.

 

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