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Mandatory Compliance: CFPB LIBOR Transition Proposed Rule, Guidance and Updated CHARM Booklet

The Bureau issued a proposed rule to amend Regulation Z to address the sunset of LIBOR, and to facilitate creditors' transition away from using LIBOR as an index for variable-rate consumer products. It also proposed changes to certain open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. The Bureau also proposed changes to certain open-end provisions restricting index changes, requiring change-in-terms notices, and addressing how credit card rate reevaluation requirements apply. A revised CHARM booklet has been provided based on consumer testing. It removed the LIBOR-based rate examples. Mandatory compliance date is set for April 1, 2022. 

  • April 1, 2022
  • Time: All Day