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Letter to the Federal Reserve regarding proposal to amend the Truth in Lending Act’s disclosure rules on Closed-End credit

December 22, 2009

Jennifer J. Johnson
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, D.C. 20551
Via email: regs.comments@federalreserve.gov

VIA FACSIMILE: (202) 452-3819

Re: Truth in Lending—Proposed Rule: Regulation Z Part 226; Docket No. R-1366

Dear Chairman Bernanke, Members of the Board, and Board Secretary Johnson:

Consumers Union, the nonprofit publisher of Consumer Reports, appreciates the opportunity to comment to the Federal Reserve Board regarding the Board’s proposal to amend the Truth in Lending Act’s disclosure rules on closed-end credit. This letter addresses only our comments regarding the changes proposed by Docket No. R-1366. Consumers Union’s comments regarding the changes proposed to the disclosures governing open-end credit, Docket R-1367, are filed under separate correspondence.

I. Summary of Consumers Union’s Comments
The changes in the disclosure rules proposed by the Board regarding closed-end lending are significant and are ones which Consumers Union supports. We also support an expansion of the substantive rules to prevent mortgage lending abuses. In this letter, we comment briefly on our position regarding the Board’s most important proposed changes. We also encourage the Board to use its authority to ban unfair mortgage practices more aggressively. In addition to our comments, we also support those provided by the California Reinvestment Coalition and the comprehensive comments submitted by the National Consumer Law Center.