The CFPB's LIBOR Transition Proposal and Guidance: What You Need To Know
In an effort to provide assistance to the consumer credit and mortgage loan industries in connection with the upcoming transition away from the London Inter-Bank Offered Rate (LIBOR) that is currently used by many creditors as the index for calculating the interest rate on credit cards and other variable-rate consumer credit products, the CFPB issued proposed amendments to Regulation Z and LIBOR Transition FAQs. The webinar will address:
- A proposed new method for credit card issuers and home equity line of credit (HELOC) creditors to transition away from LIBOR, regardless of whether LIBOR is still available.
- Indices that the CFPB proposes to deem as being substantially similar to LIBOR indices.
- Proposal regarding required change in terms notices for credit cards and HELOCs.
- Proposal to create an exception from the requirement for card issuers to periodically review increased rates when a rate increase results from the replacement of a LIBOR index.
- Proposal for closed-end credit that replacing LIBOR with certain indices that would be deemed comparable does not constitute the addition of a variable rate feature that would require new disclosures.
- Guidance regarding how and when information on the transition from LIBOR to another index may be addressed in the initial or a subsequent rate and payment adjustment notice, and in a periodic statement.