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Reserve

bank

DALLAS, TEXAS

of

Dallas

75222

C ir c ula r No. 75-107
J u ly 28, 1975
American Revolution Bicentennial

REVISED PROPOSED AMENDMENTS TO THE TRUTH-IN-LENDINC REGULATION
REGULATION Z
Fair Credit Billing Act Amendments

TO ALL BANKS, OTHER CREDITORS,
AND OTHERS CONCERNED IN THE
ELEVENTH FEDERAL RESERVE DISTRICT:
Following is the text of a statement issued July 22, 1975, by the Board of Governors
of the Federal Reserve System:
The Board of Governors of the Federal Reserve System today scheduled an in­
formal hearing, to take place August 5 and 6, on revised proposals for regulations
to implement the Fair Credit Billing Amendments to the Truth-in-Lending Act.
As indicated in the attached FEDERAL REGISTER notice, the Board outlined the
substance of the principal issues on which it desired comments, and it stated that
it planned to issue revised regulatory draft language before the hearing.
Written comment on the proposals will be received through August 12. Those
wishing to participate in the hearing should file a written request with the Secre­
tary of the Board, indicating the nature and extent of participation desired, to be
received not later than July 30, 1975.
The Board first published proposed regulations to implement the Fair Credit
Billing Amendments—which go into effect October 28, 1975—on May 5, and re­
ceived comment through June 20, 1975. It is scheduling a hearing, and it will be
issuing revised regulatory proposals, in the light of comments received.
The principal issues on which the Board asked comment include:
1.

The definition of billing error with respect to acceptance of goods.
The proposal would make it clear that there is a billing error in this
respect only if goods are not accepted because delivery has been
made late, to the wrong location, in the wrong quantity, or when the
goods are different from those described in the sales agreement.
Disputes as to quality of goods would not be included.

This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org)

-

2.

2

In place of the previous proposal requiring that creditors credit
payments as of the date received, regardless of when the payment
is posted, it is proposed that:
—

The creditor specify at least one location at which all payments
received will be credited on the day of receipt;

—

Payments received at branches or other remote locations be
posted within no more than three days, and that customers
be informed of such a possible delay;

—

With respect to accounts paid in full, credit be given so as to
avoid further finance charges.

Some period for creditors to make transition to this procedure may be neces­
sary.
3.

The original proposals specified there could be no finance charge
while a dispute over a billing error was being settled, regardless
of who was in erro r. The revised regulation proposes that finance
charges be adjusted only if the creditor was in error.

4.

The revised proposal requests comment on whether a surcharge
should be treated the same as a discount when imposed on customers
who choose to use a credit card instead of paying cash.

The FEDERAL REGISTER notice referred to above is not attached; however, those de­
siring a copy of the full text of that notice may obtain it by contacting the Secretary's Office of
this Bank.
Interested persons need not participate in the oral presentation to have their views
considered but may submit their views in writing to be received by the Secretary, Board of Gov­
ernors of the Federal Reserve System, Washington, D .C . 20551, not later than August 12, 1975.
Sincerely yours,
T . W. Plant
First Vice President