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October 23, 2012

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JC Campos

How does the fact that the term "operation of law" only appears alongside the concept of "security interest" in the final rule change the analysis? Does this exclusion now extend to all changes required by law, or does this exclusion only apply to matters related to security interests, as the example in the exclusion states?

Steve Van Beek

JC,
These are great questions for the CFPB. Unfortunately, without any further explanation credit unions need to rely solely on the language in Reg Z and the staff commentary and make their own interpretations.

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