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.

Primary Sources

  1. CFPB Press Release: CFPB Takes Steps to Facilitate LIBOR Transition
  2. CFPB FAQ: LIBOR Transition FAQs
  3. CFPB Guidance: Consumer Handbook on Adjustable-Rate Mortgages
  4. CFPB Proposed Rule Amendments: Amendments to Facilitate the LIBOR Transition (Regulation Z)

Originally published June 05, 2020

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.