United States:
AO On Private Education Loan Refinancing Or Consolidation Products
24 December 2020
Ballard Spahr LLP
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The AO addresses whether private education loan consolidation
products that satisfy and replace multiple federal, or federal and
private education loans, and private education loan refinance
products that satisfy and replace a single federal or private
education loan are "private education loans" for purposes
of the disclosure and other requirements applicable to
"private education loans" under TILA and Regulation Z.
The AO sets forth the Bureau's legal analysis on which it bases
its conclusion that such private education loan refinance or
consolidation products are covered under the term "private
education loan" in TILA and Regulation Z and therefore subject
to TILA and Regulation Z's requirements in subpart F.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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