CUNA expressed appreciation for the Consumer Financial Protection Bureau’s (CFPB) proactive effort to amend Regulation Z to facilitate the LIBOR transition for consumer financial products in response to LIBOR’s planned discontinuation after 2021. Currently, LIBOR is expected to be discontinued sometime after 2021 and the CFPB intends for a final rule on LIBOR to take effect on March 15, 2021 (except for certain change-in-term requirements for credit cards and home equity lines of credit.)
“CUNA generally supports the Bureau’s proposal and believes clarity of compliance expectations surrounding the LIBOR discontinuation is beneficial for financial institutions and, ultimately, consumers” the letter reads.
CUNA also offered additional feedback, including:
The CFPB announced plans in this proposal to issue additional written guidance related to the LIBOR transition on its website.