The Public Speaks on Regulation Z

Wednesday, December 22, 2010 , , , 1 Comments

I have no idea who this guy is but wish he'd get in touch with me, I'd like to hire him to write all my future comment letters.

First, the mission (which he chose to accept) from the Fed (and if you're really excited about giving them a piece of your mind, you've got a little less than 2 weeks to get your comments in), a buncha bullshit about credit cards:

The Federal Reserve Board on Tuesday proposed a rule amending Regulation Z (Truth in Lending) to clarify aspects of the Board's rules protecting consumers who use credit cards. The proposal is intended to enhance protections for consumers and to resolve areas of uncertainty so that card issuers fully understand their compliance obligations. In particular, the proposal would clarify that:

Promotional programs that waive interest charges for a specified period of time are subject to the same protections as promotional programs that apply a reduced rate for a specified period. For example, a card issuer that offers to waive interest charges for six months would be prohibited from revoking the waiver and charging interest during the six-month period unless the account becomes more than 60 days delinquent.

Application and similar fees that a consumer is required to pay before a credit card account is opened are covered by the same limitations as fees charged during the first year after the account is opened. Because the total amount of these fees cannot exceed 25 percent of the account's initial credit limit, a card issuer that, for example, charges a $75 fee to apply for a credit card with a $400 credit limit generally would not be permitted to charge more than $25 in additional fees during the first year after account opening.

When evaluating a consumer's ability to make the required payments before opening a new credit card account or increasing the credit limit on an existing account, card issuers must consider information regarding the consumer's independent income, rather than his or her household income.

The proposal would clarify portions of the Federal Reserve's final rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit Card Act), which was enacted in May 2009. The last of these rules went into effect on August 22, 2010.

Philadelphia Fed's Consumer Compliance Outlook has a pretty good summary of the three-part CARD act changes
and what they mean for you, stupid, debt-ridden consumer.

And with that, I humbly present to you, dear reader, Patrick Wooldridge, US Citizen and his fantastic comment:

On behalf of the people of the United States of America, I must strenuously oppose the proposed changes to the Truth in Lending Act (FRB R-1393). 1) The Federal Reserve and its member banks are clearly and directly culpable for not only the current housing crisis, but even more importantly for the crisis of confidence in the US Dollar (and in fiat currencies in general). To contemplate eviscerating one of the few protections that consumers have against the power and megalopoly [fucking sick sic] of the banks is utterly unconscionable and literally makes me sick to my stomach. The banks and bankers continue to enjoy success and their ridiculous profits and salaries while millions of citizens lose their jobs and homes. Continuing along this path will destroy our republic. One wonders whether the Fed governors even care about the health of the nation, or whether they are just building up their personal and corporate fortunes and looking forward to carpetbagging after the looming economic catastrophe. 2) For the Fed to even contemplate this resolution at this time shows tremendous contempt for the Consumer Financial Protection Bureau, the Constitution of the United States, and the rule of law in general. The CFPB was established precisely to advocate for the common man against the power and self-interest of the banks and Big Money in general. This resolution seems very much like a hurried effort by the Fed to further indenture the middle class to the economic aristocracy and protect billionaires from working people by taking advantage of this small window in time before the CFPB is fully empowered. In summary, I ask - beg, really - that the governors, the FOMC and the member banks reexamine their consciences in light of a single question: "What course of action will most strongly support the principles that all men are created equal and that government of the people, by the people, for the people, shall not perish from the earth?

Megalopoly might not be a word but damnit it should be.

JDA salutes you, Mr Wooldridge! Keep on keepin' on!

Jr Deputy Accountant

Some say he’s half man half fish, others say he’s more of a seventy/thirty split. Either way he’s a fishy bastard.


Joe Carey said...

What's the difference? The CFPB will be part of the Fed: "The Bureau of Consumer Financial Protection (CFPB) will be an independent bureau within the Federal Reserve System" . I enjoy an impassioned comment as much as the next guy, but I don't see any specific complaint about the rules proposed and they're all the same people anyway.