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F ederal reserve Bank of Dallas DALLAS, TEXAS 75222 C ir c u la r No. 78-20 F e b ru a r y 22, 1978 AM EN DM EN T T O REGULATION Z— T R U T H - IN - L E N D IN G B illin g Requirem ents fo r Cash A dvance Check Transactions TO A L L BANKS, OTHER CR ED IT O R S, AND OTHERS CONCERNED IN THE ELEVENTH FEDERAL RESERVE D IS T R IC T : T h e Board of G overnors of the Federal Reserve System has adopted an amendment modifying existing provisions of its T r u t h - i n - L e n d i n g Regulation Z , Section 2 2 6 . 7 (k ) (3) ( i i ) , relating to b illin g for cash advance check transactions. T h e amendment perm its c re d ito rs to use the date on wh ich a c re d ito r charges a cash advance check to the customer's account (the d e biting date} in b illin g customers. C red ito rs may continue to use the date a cash advance check is used by the customer (the transaction date) o r the date w ritte n on the check by the customer as pre s e n tly allow ed. H o w ever, the amendment also provides that if the date of debiting is used and the customer makes any in q u ir y about the cash advance check transaction, the in q u ir y must be treated as a notification of a b illin g e r r o r t r ig g e r in g the procedures for settling b illin g e rro rs u n d er the F air C re d it B illin g A ct. F u rth e r, a questioned b illin g that uses the deb itin g date must be treated as an erroneous b il lin g . T h is means that no finance charg e on the transaction would be allowed d u rin g the time the c re d it card issuer took to p ro v id e the customer w tih documentary evidence supporting the b i l l . T h e amendment is intended to facilitate compliance by cre d ito rs who have e x p e r i enced d iffic u lty in ascertainin g and stating on t h e ir bills the transaction dates relatin g to cash advance checks. In the lig h t of these d iffic u ltie s , the Board on September 2 announced that the date for fu ll implementation of the section of Regulation Z re la tin g to cash advance check transactions would be postponed from October 28, 1977, to March 28, 1978. T h e new amend ment, a copy of w hich is enclosed, is therefore effective on March 28, 1978. Questions concerning Regulation Z should be directed to our Consumer A ffa irs Section, E x t. 6171. Additional copies of the amendment to Regulation Z w ill be fu rn is h e d upon request to the S ec re ta ry 's Office of this B an k, Ext. 6267. S in c e re ly y o u rs , Robert H . Boykin F ir s t V ic e President Banks and others are encouraged to use the following incoming W A T S numbers in contacting this Bank: 1-800 -492 -440 3 (intrastate) and 1-8 00-527-4970 (interstate). For calls placed locally, please use 651 plus the extension referred to above. This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org) BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM TRUTH IN LENDING AMENDMENT TO REGULATION Zf and the date of the transaction®6 or the date which appears on the document or instrument evidenc ing the transaction (if the customer signed the document or instrument), or the date of debiting the amount to the account, provided that if only the debiting date is disclosed and the customer SECTION 226.7 — OPEN EN D CRED IT submits a proper written notification of a bill ACCOUNTS — SPECIFIC DISCLOSURES. ing error related to the transaction, the creditor * * * * * shall treat such inquiry as a billing error under §§226.2(j) and 226.14, and as an erroneous billing (k) *** under §226.14(b), and shall supply documentary evidence of the transaction whether or not the (3) *** customer requests it, within the time period (ii) A description of the transaction, which allowed under §226.14 for resolution of a billing characterizes it as a cash advance, loan, over error without charge to the customer. If the date draft loan, or other designation as appropriate, of debiting is disclosed, it must be reasonably and which includes the amount of the transaction identified as such on the periodic statement. Effective March 28, 1978, §226.7(k)(3)(ii) of Regulation Z is amended to read as follows (in asmuch as footnote 9(e) to §226.7(k)(3)(ii) is un affected by this amendment, the text of the foot note is not reproduced below): t For this Regulation to be complete effective March 28, 1978, retain the following: 1) Printed pamphlet as amended effective March 23, 1977; 2) Amendments effective April 11, 1977, Section 226.6, and October 10, 1977, Section 226.8; 3) Amendments effective July 20, 1977, Section 226.2, Section 226.4, Section 226.5, and Section 226.13; and 4) This slip sheet 3-28-78
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