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Fed to vote open-end disclosures
WASHINGTON (12/12/08)—The Federal Reserve Board is expected to vote on a plan next week that would make comprehensive changes to the format, timing, and content requirement for the five main types of open-end credit disclosures that are required under its Regulation Z. The types of disclosures covered include credit card application and solicitation disclosures, account-opening disclosures, periodic statements, change-in-term notices, and advertising provisions. For the most part the Credit Union National Association (CUNA) has supported the Fed's efforts to simplify the Regulation Z, but did not support the plan as written because it could unintentionally cut into products favored by credit unions and their members, such as the LoanLiner program offered by CUNA Mutual Group. CUNA and CUNA Mutual have been working closely on this issue and have met with the Fed to seek modifications to its plan. The Fed also has scheduled a vote on its unfair or deceptive practices rule, which is intended to prohibit a number of credit card practices as unfair or deceptive, and which it issued jointly with the National Credit Union Administration (NCUA) and Office of Thrift Supervision. CUNA said in a comment letter that credit unions are strong proponents of fair lending practices and proper consumer disclosures. CUNA said the regulators’ plan is appropriate because some in the marketplace have been subjecting consumers to abusive practices. However, CUNA warned of concerns with a number of operational and practical matters, and reiterated its primary concern about an ever-increasing regulatory burden on credit unions. “While credit unions do not engage in certain practices, they will still need to make disclosure changes and other revisions to meet all the requirements of the proposal,” CUNA wrote. CUNA also urged modifications in a proposed opt-out program for overdraft protection plans and case-by-case accommodations for member overdrafts. According to the Dec. 10 American Banker, the Fed is likely to back away from that proposal—at least for now. The NCUA announced Thursday that it will take a final vote on the rule at its open board meeting next Thursday. Also on the NCUA open board meeting agenda: a final rule on credit union service organizations, and a share insurance fund report.


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