Fed responds to CUNA letter on Reg Z and 0% auto financing deals

<p>WASHINGTON – CUNA received a response from the Fed to the letter it sent the agency in December regarding disclosure of auto financing terms under the Truth in Lending Act and Reg Z. CUNA Assistant General Counsel Jeffrey Bloch said the association was pleased that the Fed’s letter mentioned an Illinois case that CUNA cited in its letter as a basis for its argument that auto dealers should be required to disclose that the finance charge and annual percentage rate offered in 0% finance deals reflect the amount of any rebate the consumer may receive in place of a low-rate loan, and that consumers should be made aware that they may wind up paying more for the vehicle if they choose to accept the low interest rate over the rebate. The Fed reiterated that it intends to begin a review of Reg Z this year and plans to invite public comment on “the appropriate scope of the review generally, as well as on credit practices and products that have evolved in recent years and should be addressed specifically.” The agency said it would consider CUNA’s suggestions “in the context of this upcoming review.” “CUNA doesn’t want the 0% financing offers to be discontinued, we just want the Fed to require full disclosure of all information so consumers have all the information to make the best choices,” said Bloch.</p>