New Disclosures for Private Education Loans

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Question:

If we give a loan to someone to consolidate their existing student loans, are the private education loan new disclosures required? They are no longer in school, just refinancing the debt.

Answer:

Yes. See Supplement I, Comment 46(b)(5)-1:

"Extended expressly for postsecondary educational expenses. A private education loan is one that is extended expressly for postsecondary educational expenses. The term includes loans extended for postsecondary educational expenses incurred while a student is enrolled in a covered educational institution as well as loans extended to consolidate a consumer's pre-existing private education loans."

First published on BankersOnline.com 4/16/12