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FEDERAL RESERVE BANK
OF N E W YORK

C ircular No. 7704
September 8, 1975

REGULATION B
H e v i s e d P r o p o s a l for I mp l e m e n t i n g
t he F q u a l C r e d i t O p p o rt u n it y Act

To A ll Member B anks, and O thers Concerned,
in the Second F ederal R e se rve D istrict:

Printed below is the text of a statement issued September 5 by the
Board of Governors of the Federal Reserve System regarding a revised proposal
for a new Regulation B— to implement the provisions of the Equal Credit
Opportunity Act. The initial proposal was sent to you with our Circular
No. T 6 1 7 s dated April 25, 1975.
The Board of Governors of the Federal Reserve System today
issued for comment revised proposed regulations to implement the
Equal Credit Opportunity Act, which forbids discrimination by
creditors on the basis of sex or marital status.
Comment on the proposed regulation will be received through
September 26. The Board anticipates that it may make further
revisions in the regulation in the light of the additional comment
that is anticipated and in light of subsequent experience in
administering the regulation.
The ECOA goes into effect October 28. It makes the Federal
Reserve responsible for writing implementing regulations. Compliance
will be the responsibility of the Federal Trade Commission, the
Federal Reserve Board, the Federal Deposit Insurance Corporation,
the Comptroller of the Currency, and nine other Federal agencies. The
Act covers all who regularly extend credit to individuals, including
banks, finance companies, department stores, credit card issuers and
government agencies such as the Small Business Administration.
The Board first published proposed implementing rules— to be
called Regulation B —under the new Act on April 23, 1975, and held
hearings on May 28 and 2 9 . The revised proposals issued today
reflect Board review of comment received thus far.




(Over)

Principal changes from the proposals published previously include:
Retention of records — (Section 202.9) — Creditors are required
to keep records of a credit application for 12 months after final
action on the application (in place of the previous two years). This
parallels the limitation in the Act given to credit applicants who
claim a violation of the Act.
Keeping accounts in the name of both spouses — (Section 202.6) —
For accounts established after November 1, 1976, a creditor who
furnishes information about an account to a consumer reporting agency
or others shall furnish the information in the names of both spouses
when both are to use the account. For prior accounts, account holders
may request that the account be kept in the names of those contrac­
tually responsible for it.
Under the previous proposal the creditor would have been required
to maintain records of all accounts, whenever established, in the name
of both husband and wife.
Use of courtesy titles — (Section 202. k) — The revised proposal
does not, as previously, forbid the use by creditors of courtesy titles
in addressing applicants (such as Mr., Mrs., Ms., Miss), but provides that
the creditor must tell the applicant that the use of courtesy titles
is optional.
Information as to childbearing intentions and continued ability
to pay — (Section 202.5) — The new draft continues to forbid that
creditors demand information about childbearing capability or birth
control practices, but permits the creditor to request information
concerning the probable continuity of an applicant’
s ability to repay.
Notice of right to equal credit opportunity — (Section 202.^) —
The new draft regulation adds the requirement that such a notice be
included on any written application form used.
The draft regulation also, among a number of other changes:
(Section 202.5) — Requires notification of an applicant of action
upon the application, rather than requiring a statement of reasons for
denial.
(Section 202.3) — Revises the definition of discrimination to
mean the treatment of one applicant less favorably than others.
The text of the revised proposal will be sent to you shortly. Comments
thereon should be submitted by September 26, and may be sent to our Bank Regulations
Department.




P aul

A. V olcker,

President.