Checklist 7.1: Regulation Z
Yes
Open-End Credit
1. Are the credit and charge card early disclosures provided on or with all applications for credit and charge
cards? (12 CFR 1026.60(a))
2. Do the early disclosures for credit and charge cards contain the required information in the proper format?
(12 CFR 1026.60(b) and 12 CFR 1026.5(a) and (c)-(e)) (Note: special disclosure contents and methods
allowed for telephone, general public, and charge cards in.) (12 CFR 1026.60(d)-(f))
3. Are the early home equity plan disclosures and home equity brochure provided at the time applications for
home equity plans are provided (or mailed within three business days of receipt of an application by
telephone, broker, or applications in a magazine or other publication)?
(12 CFR 1026.40(b) and (e))
4. Are the early home equity plan disclosures in the proper form and do they contain the required
information? (12 CFR 1026.5(a) and (c)-(e), 12 CFR 1026.40(a) and (d))
5. If a non-refundable fee is imposed on a home equity line of credit, is the fee imposed only after three
business days after the consumer receives the disclosure and brochure? (12 CFR 1026.40(h))
6. Do the institution’s home equity plan loan agreements and practices follow the limitations and prohibitions
in (12 CFR 1026.40(f))?
7. Is an initial open-end credit disclosure provided to consumers for all open-end loans before the first
transaction is made under the plan? (12 CFR 1026.5(b))
8. Does the initial disclosure for all open-end credit plans contain the required information
(12 CFR 1026.6) and in the proper format? (12 CFR 1026.5(a) and (c)-(e))
9. Does the institution provide periodic statements for all required open-end accounts?
(12 CFR 1026.5(b)(2)(i))
10. Are periodic statements mailed when required? (12 CFR 1026.5(b)(2)(ii))
11. Do the periodic statements contain the required information? (12 CFR 1026.7)
12. Does the institution provide either the annual or periodic statement of billing rights?
(12 CFR 1026.9(a))
13. Does the institution provide the required disclosures when an additional feature is added to or furnishes a
credit device (e.g., credit card) for an existing account? (This does not include renewals, resupply, or the
original issuance of the card.) (12 CFR 1026.9(b))
14. Is the required change in terms notice provided whenever a term contained in the initial disclosure is
changed? (12 CFR 1026.9(c))
15. If an annual fee is imposed on a credit or charge card, is the required renewal notice provided on renewal
of the account? (12 CFR 1026.9(e))
16. If the insurance provider is to be changed for credit card accounts, is the required notice provided? (12
CFR 1026.9(f))
17. Are payments on open-end accounts credited the day they are received (or within five days if nonconforming)? (12 CFR 1026.10)
18. Are credit balances in excess of one dollar credited to the account; refunded within seven days of a
consumer’s written request; and refunded if they remain for more than six months?
(12 CFR 1026.11)
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No
19. Are credit cards issued on request or as a renewal or substitution of an accepted card?
(12 CFR 1026.12(a))
20. Is the liability for credit card holders limited to the required amounts? (12 CFR 1026.12(b))
21. When credit card holders have a claim or defense against a person who honored the credit card, are the
holders allowed to assert those claims and defenses against the institution to the extent allowed? (12 CFR
1026.12(c))
22. Does the institution prohibit offset against a consumer’s other accounts for repayment of credit card
accounts except as allowed? (12 CFR 1026.12(d))
23. Does the institution avoid the prohibited discounts and tie-in arrangements with respect to its credit cards?
(12 CFR 1026.12(f))
24. Does the institution follow the required procedures when a consumer makes a claim of a billing error on
an open-end account? (12 CFR 1026.13)
25. Is the annual percentage rate used for initial disclosures, early credit card disclosures, home equity plan
disclosures, and advertising calculated by multiplying the periodic rate by the number of periods in a year?
(12 CFR 1026.14(a))
26. Does this annual percentage rate for periodic statements include all charges that are considered finance
charges under (12 CFR 1026.4)?
27. Is the annual percentage rate for periodic statements calculated using one of the allowed methods? (12
CFR 1026.14(b))
28. For all loans to be secured by a consumer’s principal dwelling, is each consumer with an ownership interest
in the dwelling provided with two copies of the notice of their right to rescind the transaction? (12 CFR
1026.15(b))
29. For all loans subject to the right of rescission, does the institution delay providing funds and other
performance until after the three-day rescission period has expired? (12 CFR 1026.15(c))
30. When a consumer properly rescinds a transaction, does the institution return all money received from the
consumer, including amounts paid to third parties, within 20 days? (12 CFR 1026.15(d))
31. Does the institution only allow waivers of rescission in the case of bona fide personal emergencies? (12
CFR 1026.15(e))
32. If waivers are allowed, are they in writing, with printed waiver forms prohibited?
(12 CFR 1026.15(e))
33. In advertisements for open-end loans, if they state specific credit terms, do they only state those terms that
actually are or will be arranged or offered by the institution? (12 CFR 1026.16(a))
34. If advertisements for open-end loans contain “triggering terms,” do they also include the required
additional information? (12 CFR 1026.16(b)) (For catalog or other multi-page ads, note alternative
available in 12 CFR 1026.16(c).)
35. If advertisements for home equity plans include an affirmative or negative reference to any of the specific
terms required to be disclosed in an initial disclosure under 12 CFR 1026.16(a) or (b), do the ads include
the additional information? (12 CFR 1026.16(d))
36. Does the institution only use the term “fixed” in disclosures to describe the interest rate, unless they also
specify a time period that the rate will be fixed and the rate will not increase during that period (such as a
promotional rate period). If a time period is not specified and the account is described as a “fixed-rate”
account, then will the rate not be increased increase as long as the plan is open?
(12 CFR 1026.5(a)(2)(iii))
37. Timing of periodic statements (12 CFR 1026.5(b)(2)(ii))
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
Due Date — For credit card accounts under an open-end (not home-secured) consumer credit plan, does the
institution have procedures designed to ensure that:
— Periodic statements are mailed or delivered at least 21 days prior to the payment due date; and
— The card issuer does not treat as late for any purpose a required minimum periodic payment
received by the card issuer within 21 days after mailing or delivery of the periodic statement
disclosing the due date for that payment.

Grace Period — For all open-end consumer credit plans (not just credit cards). If the account offers a grace
period, does the creditor adopt reasonable procedures designed to ensure that:
— Periodic statements are mailed or delivered at least 21 days prior to the date on which any grace
period expires; and
— The creditor does not impose finance charges as a result of the loss of a grace period if a payment
that satisfies the terms of the grace period is received by the creditor within 21 days after mailing
or delivery of the periodic statement?
38. Does the institution include the following on periodic statements for all open-end plans except home
equity plans subject to the requirements of 12 CFR 1026.40:

Due date; late payment costs (12 CFR 1026.7(b)(11)),

Repayment disclosures (12 CFR 1026.7(b)(12)), and

Format requirements for periodic statement (12 CFR 1026.7(b)(13))?
39. For open-end (not home-secured) plans, does the institution provide the required prior written notice
before implementing a significant change of account terms? (12 CFR 1026.9(c)(2))
40. For credit and charge card accounts that are subject to the early disclosure requirements of 1026.60, does
the institution provide the required disclosures upon renewal of the credit or charge card?
(12 CFR 1026.9(e))
41. For open-plans other than HELOCs that are subject to 1026.40, does the institution provide the required
disclosures prior to an increase in rates due to delinquency or default or as a penalty?
(12 CFR 1026.9(g))
42. When a consumer has a right to reject a change in terms, does the institution comply with the requirements
when a consumer rejects the applicable significant changes in terms?
(12 CFR 1026.9(h))
43. For all open-end consumer accounts, does the institution have the required reasonable requirements for
repayment? (12 CFR 1026.10(b))
44. Does the institution comply with the requirements regarding crediting of payments when creditor does not
receive or accept payments on due date? (12 CFR 1026.10(d))
45. For credit card accounts under an open-end (not home-secured) consumer credit plan, does the institution
comply with the limitations on fees related to method of payment? (12 CFR 1026.10(e))
46. For accounts for which the institution is a “card issuer,” does the institution comply with the changes the
address for payments for these accounts when applicable? (12 CFR 1026.10(f))
47. For credit card accounts under an open-end (not home-secured) consumer credit plan, does the institution
comply with the requirements regarding timely settlement of estate debts? (12 CFR 1026.11(c))
48. In its advertising, does the institution only use the term “fixed” in disclosures to describe the interest rate
unless they also specify a time period that the rate will be fixed and the rate will not increase during that
period (such as a promotional rate period). If a time period is not specified and the account is advertised as
a “fixed-rate” account, then the rate will not be increased increase as long as the plan is open? (12 CFR
1026.16(f))
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Closed-End Credit
1. Is a Truth-in-Lending disclosure provided to consumers for all closed-end loans before consummation of
the transaction?
(12 CFR 1026.17(b)) (Note alternatives for multiple creditors and/or consumers under 12 CFR 1026.17(d); mail or
telephone orders under 12 CFR 1026.17(g); a series of sales under 12 CFR 1026.17(h); and student loans under 12 CFR
1026.17(i).)
2. Are the Truth-in-Lending disclosures in the proper format? (12 CFR 1026.17(a))
3. Do the Truth-in-Lending disclosures contain all of the required information about the loan?
(12 CFR12 CFR 1026.17(c) and 1026.18) (Note alternatives for multiple creditors and/or consumers under 12 CFR
1026.17(d); mail or telephone orders under 12 CFR 1026.17(g); a series of sales under
12 CFR 1026.17(h); and student loans under 12 CFR 1026.17(i).)
4. Are the disclosed annual percentage rates accurate within the allowed tolerances? (12 CFR 1026.22)
5. For loans secured by a consumer’s dwelling, are the Truth-in-Lending disclosures provided within three
business days of the date the institution receives the written application (i.e., an early Truth-in-Lending
disclosure) and at least seven business days prior to closing? (12 CFR 1026.19(a))

Does the institution impose only a fee for credit reports until the consumer receives the early TIL?

If the annual percentage rate (APR) on the early TIL becomes inaccurate, does the institution provide
an accurate TIL at least three business days before closing?
6. When early Truth-in-Lending disclosures are provided, is a new disclosure provided before consummation
if any term changes in the interim, making them inaccurate? (12 CFR 1026.17(f))
7. For loans longer than one year secured by a consumer’s principal dwelling, if the annual percentage rate
can increase after consummation, is an early adjustable rate mortgage program disclosure (early ARM
disclosure) and the booklet on ARM loans provided at the time an application form is provided (or with
three business days of receiving applications by telephone or through a broker) or before the consumer
pays a nonrefundable fee, whichever is earlier? (12 CFR 1026.19(b))
8.
Does the Early ARM disclosures contain all of the required information? (12 CFR 1026.19(b)(2))
9. Are new Truth-in-Lending disclosures provided to consumers when an existing loan is refinanced (i.e., the
existing loan is satisfied and replaced by a new obligation)? (12 CFR 1026.20(a))
10. Are new Truth-in-Lending disclosures provided to consumers who assume a residential mortgage
transaction loan? (12 CFR 1026.20(b))
11. For all loans for which an Early ARM disclosure was required, is a rate adjustment notice (ARM rate
adjustment notice) provided to the consumers at least once each year during which an interest rate
adjustment is implemented without an accompanying payment change, and at least 25, but no more than
120, calendar days before payment at a new level is due? (12 CFR 1026.20(c))
12. Do the ARM rate adjustment notices contain all of the required information? (12 CFR 1026.20(c))
13. Are credit balances in excess of one dollar credited to the account; refunded within seven days of a
consumer’s written request; and refunded if they remain for more than six months?
(12 CFR 1026.21)
14. For all loans to be secured by a consumer’s principal dwelling, is each consumer with an ownership interest
in the dwelling provided with two copies of the notice of their right to rescind the transaction? (12 CFR
1026.23(b))
15. For all loans subject to the right of rescission, does the institution delay providing funds and other
performance until after the three-day rescission period has expired? (12 CFR 1026.23(c))
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16. When a consumer properly rescinds a transaction, does the institution return all money received from the
consumer, including amounts paid to third parties, within 20 days? (12 CFR 1026.23(d))
17. Does the institution only allow waivers of rescission in the case of bona fide personal emergencies? (12
CFR 1026.23(e))
18. If waivers are allowed, are they in writing, with printed waiver forms prohibited?
(12 CFR 1026.23(e))
19. In advertisements for closed-end loans, if they state specific credit terms, do they only state those terms
that actually are or will be arranged or offered by the institution? (12 CFR 1026.24(a))
20. When advertisements for closed-end loans state a rate of finance charge, do they state the rate as an
“annual percentage rate,” using that term, and include no other rate other than the simple annual rate or
periodic rate that is applied to an unpaid balance stated in conjunction with, but not more conspicuously
than, the annual percentage rate? (12 CFR 1026.24(b))
21. When advertisements for closed-end loans state a rate and if the annual percentage rate can increase after
consummation, do the advertisements state that fact? (12 CFR 1026.24(b))
22. If advertisements for closed-end loans contain “triggering terms,” do they also include the required
additional information? (12 CFR 1026.24(c)) (For catalog or other multi-page ads, note alternative available in 12
CFR 1026.16(d).)
Miscellaneous
1. Are records of compliance with Regulation Z (other than advertising) maintained for two years?
(12 CFR 1026.25)
2. In oral responses to consumers’ inquiries about the cost of open-end credit, is only the annual percentage
rates stated (except that the periodic rates also may be stated)? (12 CFR 1026.26(a))
3. In oral responses to a consumer’s inquiry about the cost of closed-end credit, is only the annual percentage
rate stated (except that a simple annual rate or periodic rate can also be stated if it is applied to an unpaid
balance)? (12 CFR 1026.26(b))
4. For all consumer loans secured by a dwelling when (a) in the case of closed-end credit, the annual
percentage rate may increase after consummation, or (b) in the case of open-end credit, the annual
percentage rate may increase during the plan, does the loan agreement include the maximum interest rate
that may be imposed during the term of the loan? (12 CFR 1026.30)
Special Rules for Certain Home Mortgage Transactions
1. Does the institution monitor all loans secured by a consumer’s principal dwelling (except residential
mortgage transactions) for loans that meet either the “annual percentage rate” or “points and fees” test for
applicability of Section 32? (12 CFR 1026.32(a))
2. For loans subject to Section 32, is a Section 32 disclosure provided to consumers at least three business
days prior to closing? (12 CFR 1026.31(c)(1))
3. Do the institution’s Section 32 disclosures contain all of the required information?
(12 CFR 1026.31(d) and 1026.32(c))
4. If any changes in the terms of loans subject to Section 32 are made after the disclosure is provided, is a
new disclosure provided reflecting the new terms at least three business days before closing? If not, are the
changes initiated by the consumer and the required telephone and written disclosures provided? (12 CFR
1026.31(c)(1)(i) and (ii))
5. Are waivers of the three-day waiting period prohibited except in cases of bona fide personal emergencies?
(12 CFR 1026.31(c)(1)(iii))
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6. If waivers are allowed, are they in writing, with printed waiver forms prohibited?
(12 CFR 1026.31(c)(1)(iii))
7. Do the institution’s loan agreements for loans that are subject to Section 32 exclude the prohibited terms?
(12 CFR 1026.32(d))
8. Does the institution avoid the prohibited acts and practices with respect to loans subject to Section 32? (12
CFR 1026.34)
9. For reverse mortgage loans, does the institution provide consumers with a reverse mortgage disclosure at
least three business days prior to (i) consummation of a closed-end credit transaction; or (ii) the first
transaction under an open-end credit plan? (12 CFR 1026.31(c)(2))
10. Do the institution’s reverse mortgage disclosures contain all of the required information?
(12 CFR 1026.31(d) and 1026.33(b))
11. For loans subject to 1026.32, does the institution comply with all of the prohibited acts and practices of
1026.34? (12 CFR 1026.34)
12. For higher priced mortgage loans, does the institution comply with all of the prohibited acts and practices
of 1026.35? (12 CFR 1026.35)
13. Does the institution comply with the prohibited acts or practices in connection with credit secured by a
consumer’s principal dwelling? (12 CFR 1026.36)
14. For consumer credit transactions that are secured by the principal dwelling of a consumer, does the
institution comply with the transfer of mortgage servicing notice requirements? (12 CFR 1026.39)
Subpart G — Special Rules Applicable to Credit Card Accounts and Open-End Credit
Offered to College Students
1. For applications for credit card accounts for a consumer under an open-end (not home-secured) consumer
credit plan, does the institution comply with the requirements for evaluating the consumer’s ability to
repay? (12 CFR 1026.51)
2. For credit card accounts for a consumer under an open-end (not home-secured) consumer credit plan,
does the institution comply with the limitations on fees? (12 CFR 1026.52)
3. For credit card accounts for a consumer under an open-end (not home-secured) consumer credit plan,
does the institution comply with the allocation of payments requirements? (12 CFR 1026.53)
4. For credit card accounts for a consumer under an open-end (not home-secured) consumer credit plan,
does the institution comply with the prohibition against double cycle billing?
(12 CFR 1026.54)
5. For credit card accounts for a consumer under an open-end (not home-secured) consumer credit plan,
does the institution comply with the limitations on increasing annual percentage rates, fees, and charges?
(12 CFR 1026.55)
6. For credit card accounts for a consumer under an open-end (not home-secured) consumer credit plan,
does the institution comply with the requirements for over-the-limit transactions?
(12 CFR 1026.56)
7. Does the institution refrain from offering college students any tangible item to induce such student to
apply for or open an open-end consumer credit plan on or near campuses or campus-sponsored events?
(12 CFR 1026.57
8. Does the institution comply with the reporting requirements for marketing agreements with
colleges/universities? (12 CFR 1026.57)
9. For institutions who have 10,000 or more open credit card accounts, does the institution post the required
credit card agreements on its web site and submit them to the Federal Reserve?
(12 CFR 1026.58)
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10. Evaluation of increased rate. If the institution increases an annual percentage rate that applies to a credit
card account under an open-end (not home-secured) consumer credit plan, based on the credit risk of the
consumer, market conditions, or other factors, or if the institution increased such a rate on or after January
1, 2009, and 45 days’ advance notice of the rate increase is required under 1026.9(c)(2) or 1026.9(g), did the
card issuer: (12 CFR 1026.58)

Evaluate the factors described in 1026.9(d), below; and

Based on its review of such factors, reduce the annual percentage rate applicable to the consumer’s
account, as appropriate?
Comments:
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