EXCERPT:
TILA is designed to protect consumers who are not on an equal footing with lenders,
either in bargaining for credit terms or in knowledge of credit provisions. The proposed
amendments to Reg. Z, conditioning the voiding of the creditor’s security interest upon
the consumer’s tender, would be a large step backward from this purpose. In a time of
unprecedented numbers of foreclosures, it is unthinkable that the Federal Reserve would
weaken a critical provision of TILA and thus harm consumers.
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I commend the sending of the letter, but quesiton if the FRB is the best source to rely upon completely. Their last several amendments clearly demonstrate either a lapes in memory as to what TILA is all about, or a shift to pro-lenders.
This would appear to be an excellent issue to present to the new Consumer Protection recently signed into existance, along with the members of Congress who have shown an awareness and concern regarding further erosion of TILA.
I also thought that this would be a great time to have REGZ and the Commentary amended to include the provision of SOSA v. FITE 465 F2d 1227 and especially 498 F2d 114 to clarify the effect of tenering at the same time as rescinding (wherein the two periods run at once and lender’s security and right to principal all disappear at the end of 20 days).