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October 02, 2009



With regard to the 45 day advance notice, according to the Interim Final Rule, if the consumer agrees to the change the notice does not have to be sent. Is this addressed further in the newest proposal? Also . . . does it go without say that the 6 month maintenance is also not necessary if the consumer agrees to the change?


Please disregard the first question -- page 377!

Steve Van Beek

Also, for question #1 - see the staff commentary on pages 666-667.

For the second question, the Federal Reserve did not address the six-month "look-back" provision in this proposal. It will be addressed in the 3rd stage of proposals because the effective date is August 22, 2010.

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