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110

S-424
R.eg.W
BOA.R.D OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
INT1'~.PR.ETA1'ION

0 F LAW OR REGULATION

January 9, 1942

W-124. Interpretation W-16 dealt with a case in which
a dealer sells a listed article but does not take a. note from
the customer payable to t:1e dealer, and instead, according to
arrangeiJlents \vith a bank, takes a note payable to the ba.YJ.k. W-16
stated that the transaction constitutes an extension of instalment
sale credit within the f!ieaning of section 2(d) of Hegulation W.
The Board has recently been asked whether the t:::-ansaction also
constitutes an extension of instahnent loan cre-J.it, in which
event a "Stat·.::ment of Borrowor" would have to be taken in connection with the transaction.
It is the view of the Board that such a transaction
does not constitute an extension of instalment loan credit since,
under section 2(0) of the Regulation, instalment lo~m credit includes cn1y specified transactions "other than instalment sale
credit".
It is to he noted, of course, that the definition of
instalment sale credit in section 2(d) is OJ its terms co1;.fined
to transactions ilwolving a listed article, and that accordingly
if the article involved WGre urilisted, the trrmsc..ction might, as
indicnted in the last p:c.rn.graph of W-119, be an extension of instalment loan credit.