Regulation Z: Truth in Lending, Federal Reserve Board Docket No. R-1384
Consumers Union, the nonprofit publisher of Consumer Reports, appreciates the opportunity to comment on this proposal to amend Regulation Z and implement certain provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (the CARD Act.)
We recommend that the proposed rule be amended to go further in a number of ways to adequately address abusive penalty fees and the drastic rate increases which creditors imposed on their customers during 2009 and the beginning of 2010, prior to the February 22, 2010 CARD Act implementation date.