On July 30, 2008, the Board of Governors of the Federal Reserve System (“Board”) published in the Federal Register (pages 44522 – 44614) its final rule (the “final rule”) amending Regulation Z and its Official Staff Interpretations. This memorandum will address only those sections of the final rule that amend the advertising requirements of Regulation Z set out in Sections 226.16 (open-end home equity plans) and 226.24 (closed-end consumer credit transactions). These advertising amendments will impact the way creditors advertise open-end home equity plans and closed-end consumer credit transactions for advertisements occurring on or after October 1, 2009. In the near future, we will issue additional memorandums to address the following sections of Regulation Z amended by the final rule: (i) HOEPA Loans (Sections 226.32 and 226.34); (ii) Higher-priced Mortgage Loans (new Section 226.35); and, (iii) Primary Dwelling Loans (new Section 226.36). On January 9, 2009, we issued a memorandum addressing the final rule’s amendments to the early disclosure requirements of Section 226.19(a)(1). Text of the Final Rule Amendments: The full text of the final rule can be printed from the Federal Register website by clicking on: http://edocket.access.gpo.gov/2008/pdf/E8-16500.pdf. The advertising amendments are in the above issue of the Federal Register on pages 44599 – 44600 for Section 226.16 and pages 44601 – 44602 for Section 226.24. Their Official Staff Interpretations are also in the above issue of the Federal Register on pages 44605 – 44606 for Section 226.16 and pages 44608 – 44610 for Section 226.24.

Complete Memorandum