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Reg E: Requiring Autopay on Debt Settlements

  • 1.  Reg E: Requiring Autopay on Debt Settlements

    This message was posted by a user wishing to remain anonymous
    Posted 04-21-2022 12:29 PM
    This message was posted by a user wishing to remain anonymous

    I wanted to gather some thoughts from this community regarding Regulation E and recurring autopay.

    Abundantly aware a bank cannot require borrowers to set up recurring autopay on a loan.

    However, Reg E does not contemplate collections well if the borrower does not honor the payment agreement and goes into a collection status, where the original agreement is modified.

    What are the various opinions about a bank that might have a "settlement" program where the original loan is discounted, accruing interest is stopped, but borrowers are required to opt into autopay to take advantage of the offer?