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FEDERAL RESERVE BANK O F NEW YORK r Circular No. 7 9 5 2 - 1 L September 13, 1976 J AMENDMENTS TO REGULATION Z Identification of Transactions; Miscellaneous Amendments T o A ll M e m b e r B a n k s, an d O th e r s C o n cern ed , in th e S e c o n d F e d e r a l R e s e r v e D i s t r i c t : Following is the text of a statem ent issued A ugust 31 by the Board of Governors of the Federal Reserve System : T he B oard of G overnors of the F ederal Reserve System today announced adoption of changes in its Regulation Z (T ru th in L ending) for identifying transactions charged to consum ers using open-end charge accounts such as charges on credit card billing statem ents, or departm ent store accounts. T he action is effective immediately. T h e am endm ents to R egulation Z, as adopted, differed only slightly from proposals published for com m ent M ay 12, 1976. T h e portions of R egulation Z am ended by the B oard were originally adopted effective last O ctober 28, together w ith other am endm ents to the regulation im plem enting the separate but related F a ir C redit Billing Act. T h e original identification-of-transaction rules would have required that, effective July 1, 1976, when other inform ation was not available to identify a sale, a num ber or symbol (fo r instance, a voucher nu m b er) m ust appear on the billing statem ent. T he M ay 12 proposal to change this rule suspended the Ju ly 1 deadline. A s adopted, this provision is am ended as follow s: — In a tw o-party transaction (generally involving only the custom er and the m erchant) if the seller can not provide a description of the property or services otherw ise required to identify the transaction on a billing statem ent, a voucher num ber m ay be used instead. — If, how ever, the custom er cannot identify the transaction from the voucher num ber, the creditor would be required to treat any resulting inquiry from the custom er as a billing error. T his would trig g er the billing e rro r settlem ent procedures under the F a ir C redit Billing A ct, including: no finance charge on the transaction until the m atter is settled, an additional period free of finance charges if the creditor norm ally allows such a period after billing, and provision of a copy of the sales voucher to the custom er w ithout charge. C reditors in th ree-p arty transactions (involving the custom er, m erchant and credit card issuer other than the m erchant) would have had this alternative available to them under the M ay 12 proposals, but not under the am endm ent as adopted. T h e am endm ents a ls o : — Provide th at, w hen a transaction did not take place at a seller’s fixed business location, an appropriate identifying designation m ay be used for transactions that take place by mail, by phone, at a custom er’s home or on a public conveyance, such as a plane o r train. — In the case of purchases in a foreign country, allow the creditor to identify the transaction by date of debit, instead of date of purchase, and require the creditor to tre a t any resulting inquiry by the custom er as trig g erin g the F a ir C redit Billing A ct billing e rro r procedures. — P rovide th at disclosure of a seller’s name in the same way as it appears on a sales voucher is adequate identification of the seller. T h e attached copy of the B o ard ’s am endm ents to R egulation Z include a num ber of other changes, of a technical n a tu re , not related to identification of transactions. In subm itting the amendments for publication in the F ed era l R e g is te r , the Board of Governors made the following additional statem ent: O n Septem ber 19, 1975, the B oard published am endm ents to R egulation Z in the F e d e r a l R e g i s t e r setting forth disclosure requirem ents for identifying transactions reflected on open end credit account periodic state m ents and for other purposes (40 F R 4320). Subsequently, questions w ere raised regarding these req u ire m ents and on M ay 18, 1976, the B oard published for com m ent in the F e d e r a l R e g i s t e r (41 F R 20421) proposed am endm ents intended to clarify certain requirem ents, add flexibility as necessary, and insure th at consum ers would be able to procure complete inform ation regarding their open end credit accounts quickly an d w ithout undue expense. r Com m ents w ere received and analyzed during the com m ent period, which ended June 18. O n the basis of those com m ents and its ow n analysis the B oard has adopted the regulations which follow. I d e n tific a tio n o f T r a n s a c tio n s U n d er these am endm ents the requirem ents for identifying transactions on open end credit periodic state m ents are changed in the following w a y s : 1 . T o enhance the clarity of the text, a new section 226.7 (k ) is added to the Regulation. T his new section would contain the requirem ents for identifying transactions. Section 2 2 6 .7 (b ) (1) ( i i ) , which form erly con tained the identification-of-transactions requirem ents, would merely reference §226.7(k) and require th at the disclosures set forth therein be m ade on or w ith periodic statem ents. 2. A s adopted in the Septem ber 19 publication, the Regulation required the creditor to provide a ref erence num ber or identifying symbol (such as a sales voucher num ber) which appears on the docum ent evidencing the transaction in those cases in which the prim arily required inform ation is not available. Because of questions th a t w ere raised regarding the usefulness of the num ber or symbol to the consum er and regarding the cost to creditors of in stituting a capability to capture the num ber or symbol for potential use in all tra n s actions w hen it may, in fact, be needed for only a few, the Board proposed in its M ay 18 publication to perm it a creditor to provide an identifying num ber or symbol when any of the prim arily required inform ation is not available or, alternatively, to perm it the creditor to disclose only th at inform ation which is available and treat any inquiry regarding the description or identification of the transaction as a billing e rro r and an erroneous billing subject to the provisions of §226.14. F u rth e r, under the proposal of M ay 18, the creditor would have been required to provide docum entary evidence of the transaction w ithout charge. These alternatives w ere to be available to those creditors th a t have procedures in place adapted to provide the prim arily required inform ation. A s finally adopted herein a creditor may not supply m erely a voucher num ber when, despite the m ain tenance of procedures reasonably adapted to procure the prim arily required inform ation, the creditor fails to obtain it. In such cases these am endm ents require the creditor to treat any inquiry as a billing erro r and an erroneous billing and, unless previously furnished w ith a periodic statem ent, provide copies of docum en ta ry evidence of the transaction free of charge. P roviding an identifying num ber or symbol would, of course, be perm issible. F u rth e r, creditors th at use “ descriptive” billing systems are required to substitute the date of debiting the am ount of a transaction to the account for the prim arily required date w henever the prim arily required date is not available and tre a t any inquiry reg ard in g the absence of the date as a billing e rro r and an erroneous billing under the procedures discussed previously herein. Previously, the regulations and p ro posals for com m ent had required th at the identifying num ber or symbol be substituted w henever the prim arily required date was not available. It seems th at the debiting date is a m ore useful substitute for the prim arily required date. T his addition to the R egulation is designed to provide an alternative to the requirem ent th at an identi fying num ber or symbol be provided in all cases when the prim arily required inform ation is not available. It is designed to insure a better and m ore complete description to the custom er w ithout financial disadvantage, to provide creditors w ith an alternative to the costly requirem ent of developing the additional capability to provide a voucher num ber for all transactions when their systems are designed to provide the prim ary inform ation, and to supply an incentive for the creditor to provide a complete description in the first instance. A s noted above, under this alternative the creditor rem ains obligated to m aintain procedures reasonably adapted to procure the prim arily required inform ation. 3. In the M ay 18 proposal, the B oard asked for com m ent regarding difficulties, and possible solutions to those difficulties, which creditors m ay have regarding describing property or services purchased in tra n s actions at m erchant establishm ents which sell a single homogeneous line of m erchandise or which use a central checkout facility. A significant proportion of the com m ents received addressed this issue, pointing out that in these tw o-party situations it is often inconvenient to the custom er and burdensom e and time consum ing to the creditor to itemize the property or services purchased in such transactions. T he regulation is, therefore, am ended herein to provide th at a tw o-party creditor m ay freely substitute a voucher num ber or other iden tifying symbol which appears on th e docum ent evidencing the transaction for the description of property or services. H ow ever, if this alternative is used custom er inquiries m ust be treated as billing erro rs and erroneous billings u nder §226.14 and, if a proper w ritten notification of a billing e rro r is received regarding the descrip tion of the goods o r services, the creditor m ust provide the custom er w ith docum entary evidence of the tra n s action. T his is m eant to be a generally available alternative which a creditor may use to program its billing system in the first instance. T h is alternative will allow the creditor to evaluate and make its own m arket judgm ent as to w hether to provide the m ore com plete description and avoid, to a large extent, the billing e rro r resolution process which m ay otherw ise result from using a voucher num ber system or, alternatively, to institute the voucher num ber system and face the potential expense of answ ering the inquiries which may be engendered thereby. This solution to the problem was suggested in some of the comments. As discussed fu rth er in a later paragraph herein, a tran sitio n period is provided to enable creditors to design systems which will comply w ith the ulti mate requirem ents of the A ct or the Regulation by O ctober 28, 1977. D uring this transition period some experience m ay be gained using the voucher num ber alternative and, to the extent that it may be represen tative, may aid creditors in determ ining w hether this type of system should be used.4 4. T his am endm ent provides an alternative sim ilar to that discussed in paragraph 2 for the transition period which lasts until O ctober 28, 1977, provided to enable creditors to ad ju st forms, procedures, and 2 com puter program s. D uring the transition phase these am endm ents allow the creditor to provide th at inform a tion which is available while requiring th at any inquiry regarding the identification of the transaction be treated as a billing erro r and as an erroneous billing w hen the prim arily required inform ation is not available. T he am endm ents also retain the alternative of supplying the identifying num ber or symbol when prim arily required inform ation regarding the m erchant’s nam e and address or description of property or services is not available d uring the transition period. F u rth e r, d u rin g the transition period the date of debiting an am ount to the account may be substituted for the otherw ise required dates. T h e language regarding the transition period for compliance, which ends O ctober 28, 1977, has been changed from the Septem ber 19 publication in two respects. F irst, the language has been changed to fu rth er clarify the fact that the alternatives provided in the section are generally available and th at creditors do not need to institute procedures reasonably adapted to procure the inform ation which will be required to be disclosed after O ctober 28, 1977, during this transition phase. Second, because of the im portance and com plexities of the issues involved and the need for interested parties to fully evaluate the requirem ents of this R egulation, the B oard has extended the beginning date of the second tran sitio n period tow ard compliance w ith the ultim ate requirem ents of the regulation to O ctober 28, 1976. T he B oard believes this to be adequate tim e, given the earlier rulem aking proceedings on this sub ject, for interested parties to adapt their procedures to the rule. Because of the need for this added transition period as reflected by the issues raised by the com m ents, the B oard herein rescinds its earlier suspension of the tran sitio n period. No requirem ents other than those embodied in earlier rulem aking proceedings have been im posed during the tran sitio n periods. 5. T hese am endm ents provide guidance regarding the disclosure of an address for certain types of threeparty transactions which are not encom passed w ithin the usual scenario of a purchase m ade at a fixed seller location. R ecognizing th at it is often problem atic to assign one address or designation which is helpful to custom ers in all situations (fo r exam ple, w ith a transaction th at occurs by telephone, mail order, in the custom er’s home, o r at a nonfixed location, such as aboard a public conveyance), the am endm ents provide some flexibility. T hey perm it the creditor to (a ) om it the address in cases w here supplying an address would, in itself, be m isleading, or (b ) supply an address or appropriate designation (such as “mail o rd e r” ), which, in the cred ito r’s opinion, is helpful in identifying the transaction or relating the transaction to a docu m ent previously furnished. U se of the disclosure provisions of this paragraph should not be for the purpose of evading o r circum venting the A ct o r R egulation, however. 6 . G uidance for disclosing the seller’s nam e for th ree-party transactions is provided. Previously, the creditor was required to disclose a seller’s name which appeared on the sales voucher. T h e M ay 18 publication provided th at if the nam e on the voucher was alphabetically abbreviated a m ore complete spelling could be provided. It fu rth er provided th at if the nam e was encoded on the sales voucher in a m anner not u n d erstan d able to custom ers the encoded symbol and a m ore com plete spelling of the seller’s nam e m ust be provided on or w ith the periodic statem ent. T his provision was designed to provide certainty in the m ethod of disclosure and to provide a description which a custom er can verify and understand. Some creditors commented that the Regulation needed m ore flexibility in this respect and th a t they should be perm itted to provide a seller’s nam e other th an by reference to w hat appears on the sales voucher. T he R egulation as finally adopted provides that disclosure of a seller’s nam e which appears on a sales voucher (o r a m ore complete spelling of such a nam e if it has been alphabetically abbreviated) is adequate. H ow ever, the R egulation no longer r e q u i r e s th at this be the name disclosed. O ther names may be adequate for these purposes as well. T h e Regulation, therefore, provides the certainty th at some creditors desire and the flexi bility others feel they need. 7. F ootnote 9b (footnote 7c as it appeared in the Septem ber 19 am endm ents) has been positioned w ithin the R egulation to indicate that all references to “the same person or related persons” in §226.7(k ) are governed by the guidelines set forth in th a t footnote. 8 . Section 226.7 (k ) (1) regarding “country club” billing has been changed from the M ay 18 publication by the addition of the w ords “ at the cred ito r’s option” im m ediately preceding the w ords “either the date of the transaction or the date the transaction is debited to the custom er’s account.” T h is is intended to allow “country club” billers to program their systems and to choose between providing the date of transaction or the date of the debiting. W hichever m ethod they choose for any particular types of transactions should be consistent. Should the date which they choose to disclose be unavailable despite procedures instituted to capture th at date, the alternative to tre a t the absence of the inform ation as a billing e rro r and an erroneous billing, as discussed earlier, would be available to them. 9. R ecognizing the difficulties of p rocuring the prim arily required inform ation for transactions in foreign countries, the am endm ent allows the creditor to (a ) disclose the date on which the am ount of the transaction is debited to the custom er’s account instead of any other required date and (b ) use the e rro r reso lution procedure discussed in paragraph 2 in all cases w ithout the obligation to m aintain the procedures adapted to procure the inform ation in every instance. T his provision is m eant to be perm issive and a creditor may, of course, disregard it and fully comply w ith the requirem ents otherw ise im posed by § 2 2 6 .7 (k ). M is c e lla n c o u s A m e n d m e n ts T h e m iscellaneous am endm ents as proposed in the M ay 18 publication are herein adopted. 1. T h e proposal am ends §226.7 (b ) (1) (iii) to provide th a t the date of crediting a paym ent or credit to the custom er’s account need not be disclosed in those situations w here the failure to credit on any particular day will not result in the im position of any finance charges or other charges upon the custom er. T his am endm ent is adopted in the belief th at such a disclosure is of little or no value or economic concern to the consum er but does impose a susbtantial cost upon creditors to make the necessary changeover for their billing system s if they have not provided such a date heretofore. T he requirem ent th at paym ents to a custom er’s account be credited prom ptly, how ever, are not changed or suspended. 2 . T h e am endm ent to §226.7 (c ) (1 ) is intended to clarify the B oard’s intent in its publication of Septem ber 19, 1975. T h e language of § 2 2 6 .7 (c )(l) perm its certain inform ation to be disclosed other than on the face of the periodic statem ent provided th at the totals of the respective debits and credits under each of the parag rap h s referenced therein are disclosed on the face of the periodic statem ent. Concern has been expressed th at the section, as am ended by the Septem ber 19 publication, required disclosure of the total of all purchases or other loan transactions and finance charges on the face of the periodic statem ent. T his was not the B o ard ’s intent. 3. T he am endm ent to §226.13(i) adds a footnote to paragraph 4 specifically perm itting the creditor to rep o rt disputed am ounts under §226.13(i) as “ in d ispute” but not as “delinquent.” T his is consistent w ith the treatm en t of credit reports under §226.14 and avoids the implication th at creditors m ust have a dual credit rep o rtin g system which would have to reflect the different kinds of disputes that m ay be raised. Enclosed is a copy of the amendments to Regulation Z. Questions thereon may be directed to our Bank Regulations D epartm ent. A dditional copies of the amendments will be furnished upon request. P a u l A. V olcker, President. 4 Board of Governors of the Federal Reserve System TRUTH IN LENDING A M E N D M E N T S T O R E G U L A T IO N Z O n A ugust 27, 1976, Regulation amended, as follo w s: Z was 1. T o fully im plem ent §411, T itle IV , Pub. L. 93-495, subparagraph (ii) of § 2 2 6 .7 (b )(l) will be amended, and a new p aragraph (k ) of §226.7 will be added, to read as follows : S E C T IO N 226.7— O P E N E N D C R E D IT A C C O U N T S — S P E C IF IC D IS C L O S U R E S * * * (b ) P e rio d ic statem en ts re q u ire d . (1 ) *** * * * (ii) T he inform ation required by § 2 2 6 .7 (k ). * * * (k ) Id e n tific a tio n of tran sactio n s. (1 ) Each extension of credit for which an actual copy of the docum ent evidencing the credit transaction (w hich does not include a so-called “ facsimile d raft” ) accom panies the periodic statem ent on which the transaction is first reflected shall be identified by disclosing on the periodic state m ent, or on accom panying sta te m e n t(s) or d o cu m e n t(s), the am ount of the transaction and, at the cred ito r’s option, either the date of the transaction or the date the transaction is debited to the custom er’s account. (2 ) Each extension of credit for which an actual copy of the docum ent evidencing the credit transaction does not accom pany the pe riodic statem ent shall be identified by disclosing on or w ith the periodic statem ent on which th at credit transaction is first reflected at le a s t: (i) F o r transactions in which the creditor and the seller are the same person or related persons ,911 the am ount of the transaction, the date on which the transaction took place,9c and a brief identification 911 of any property or ser vices purchased or an identifying num ber or symbol reasonably unique for that transaction with that creditor which appears on the docu m ent evidencing the transaction given to the c u sto m e r; provided, th at, if the creditor dis closes such an identifying num ber or symbol, the absence of the identification of the property or services otherw ise required m ust be treated as a billing erro r under §§ 2 2 6 .2 (j) and 226.14 and as an erroneous billing under §226.14(b) if the custom er subm its a proper w ritten notice of a billing erro r relating to such absence, and the creditor m ust provide docum entary evidence of the transaction to the custom er free of charge w hether o r not the custom er requests it. (ii) F o r transactions in which the seller and the creditor are not the same person or related persons, the am ount of the transaction, the date on which the transaction took place, and the seller’s nam e and the address (city and State or foreign country, using understandable and generally accepted abbreviations if the creditor desires) w here the transaction took place. (3 ) N otw ithstanding the provisions of § §226.7 ( k ) ( 1 ) and 226.7 ( k ) ( 2 ), transactions involving nonsale credit, such as a cash advance 9b For purposes of §226.7(k) a person is not related to the creditor simply because the person and the credi tor have an agreement or contract pursuant to which the person is authorized to honor the creditor’s credit card under the terms specified in the agreement or con tract. Franchised or licensed sellers of a creditor’s prod uct shall be considered to be related to the creditor for purposes of §226.7 (k ). Sellers who assign or sell open end customer sales accounts to a creditor or arrange for such credit under an open end credit plan which allows the customer to use the credit only in trans actions with that seller shall be considered related to the creditor for purposes of §226.7 (k ). 9c With respect to transactions which are not billed in full on any single statement but for which precom puted instalments are billed periodically, the date the transaction takes place for purposes of §226.7(k) shall be deemed to be the date on which the amount is debited to the customer’s account. 9d For purposes of §226.7 (k ), designations such as “merchandise” or “miscellaneous” shall not be consid ered sufficient identification of property or services, but a reference to a department in a sales estab lishment which accurately conveys the identification of the type(s) of property or services which are available in such department shall be sufficient under this para graph. Identification may be made on an accompanying slip or by symbol relating to an identification list printed on the statement. For this Regulation to be complete, retain: 1) Regulation Z pamphlet, effective October 28, 1975. 2) Amendments effective July 30 and August 6, 1976. 3) This slip sheet. PRINTED IN NEW YORK [E nc. C ir . N o. 7952] cedures reasonably adapted to procure the in form ation otherw ise required by § 2 2 6 .7(k). or an o v erdraft or other checking plan tra n s actions, shall be identified on or w ith the peri odic statem ent upon which the transaction is first reflected by providing at le a s t: ( 6 ) In complying w ith the disclosure re quirem ents of §226.7(k) ( 1 ) , ( 2 ) , (3 ) , or (4 ) : ( i) A n actual copy of the docum ent evidenc ing the transaction which shows the am ount of the transaction and either the date of the tra n s action, the date the transactio n was debited to the custom er’s account, or the date placed on the docum ent or instrum ent by the custom er (if the custom er signed the docum ent o r in stru m ent) ; or (i) T he creditor may rely upon and disclose the inform ation supplied by the seller w ith re spect to the date and am ount of transactions for which the creditor and the seller are not the same person or related persons. (ii) W ith regard to disclosing the seller’s address w here the transaction took place for purposes of §226.7(k ) ( 2 ) ( ii) , the creditor may omit the address or provide an address or other suitable designation which, in the cred ito r’s opinion, will assist the custom er in identifying the transaction or in relating the transaction, as reflected, to a do cu m en t(s) evidencing the transaction previously furnished when no m ean ingful address is readily available because the transaction took place at a location which is not fixed (fo r exam ple, aboard a public convey an ce), or in the custom er’s home (in which case “custom er’s hom e” or a sim ilar descrip tion is sufficient) or because the transaction was the result of a mail or telephone order (in which case “telephone o rd er,” “mail o rd er,” or sim ilar description is sufficient) ; provided th at any such disclosure m ade or om itted shall not be for the purpose of circum vention or evasion of this P art. (ii) A description of the transaction, which characterizes it as a cash advance, loan, over draft loan, or other designation as appropriate, and which includes the am ount of th e tran sac tion and the date of the transaction 96 or the date which appears on the docum ent or instrum ent evidencing the transaction (if the custom er signed the docum ent o r in stru m en t). (4 ) If, despite the m aintenance of proce d ures reasonably adapted to procure the infor m ation required by § §226.7(k) ( 1 ), ( 2 ), and ( 3 ) such inform ation is unavailable to the credi to r, the date of debiting the am ount to the account shall be substituted for the date o th er wise required (except th at the date of debiting need not be provided if an actual copy of the docum ent evidencing the transaction is p ro vided w ith the periodic statem en t) and the creditor shall disclose as m uch of the other required inform ation as is available and omit any inform ation w hich is not available, p ro vided, th at, if the custom er subm its a proper w ritten notification of a billing e rro r relating to the absence of the prim arily required date or other inform ation, such absence shall be treated as a billing e rro r und er § § 2 2 6 .2 (j) and 226.14 and as an erroneous billing under §226.1 4 (b ) and, unless previously furnished w ith a periodic statem ent, docum entary evi dence of the transaction m ust be furnished w hether o r not the custom er requests it, w ithin the tim e period allowed in §226.14 for resolu tion of a billing erro r, w ithout charge to the custom er. (iii) W ith regard to disclosing the seller’s name for purposes of §226.7(k) (2 ) ( ii) , dis closure of a seller’s nam e which appears on the docum ent evidencing the transaction (o r a more complete spelling of such a name if the name is alphabetically abbreviated on the document evidencing the transaction) is sufficient for purposes of §226.7(k ) ( 2 ) (ii). (7 ) (i) A s an alternative to the provisions of §§226.7(k ) (1 ) through 2 2 6 .7 ( k ) ( 5 ) , from O ctober 28, 1976, until O ctober 28, 1977: (A ) the creditor may disclose the date of debiting the am ount of the transaction to the custom er’s account for the date of the tra n s action or the date placed on the document evidencing a credit transaction if, due to opera tional lim itations, either such date is unavail able to the creditor for purposes of billing; and the creditor may disclose an identifying num ber or symbol which appears on the docu m ent evidencing the credit transaction given to or used by the custom er at the tim e of or in connection w ith the credit transaction in place of the seller’s nam e and address or description of the property or services purchased if, due to operational lim itations, such inform ation is u n available to the creditor for purposes of b illin g ; or (B ) the creditor may identify the transaction by disclosing such inform ation as is reasonably available and treatin g the absence of the infor (5 ) In any case in which a transaction oc curs oth er th an in a S ta te : (i) T h e creditor m ay disclose the date of debiting the am ount of the transaction to the open end credit account in place of any other date required elsew here in §226 .7 (k ) ; and (ii) T he provisions of § 2 2 6 .7 (k )(4 ) shall apply and the creditor need not m aintain p ro 96 In cases in which an amount is debited to a cus tomer’s open end credit account under an overdraft checking plan, the date of debiting the open end credit account shall be considered the date of the transaction for purposes of this paragraph. 2 m ation required by §226.7(k) ( 1 ) , ( 2 ) , or ( 3 ) , as applicable, as a billing erro r, as provided in §§226.2 ( j ) and 226.14. If a custom er subm its a proper w ritten notification of a billing erro r relating to the absence of such inform ation and the inform ation was, in fact, not disclosed as required by § 226.7(k) ( 1 ) , (2 ) , or ( 3 ) , as applicable, the transaction shall be treated as an erroneous billing under §226.1 4 (b ) and docum entary evidence of the transaction m ust be furnished w hether or not the custom er re quests it (despite the provisions of § § 2 2 6 .2 (j) and 2 2 6 .1 4 ( a ) ( 2 ) ) , w ithin the tim e period al lowed in §226.14 for resolution of a billing e r ror, w ithout charge to the custom er. under p arag rap h ( b ) ( l ) ( i i ) of this section and item ization of the am ounts and dates required to be disclosed under paragraph (b ) ( 1 ) (iii) of this section and of the am ount of any finance charge required to be disclosed under p arag rap h (b ) ( 1 ) (iv ) of this section may be made on the reverse side of the periodic statem ent or on a separate accom panying statem ent ( s ) , provided th at the totals of the respective debits and cred its under each of those paragraphs are disclosed on the face of the periodic statem ent. 4. Section 226.13 (i) (4 ) is am ended to add a footnote as follows: (ii) T h e effective date of §§226.7(k) (1 ) throu g h 2 2 6 .7 ( k ) ( 7 ) ( i ) , inclusive, is O ctober 28, 1976. U n til O ctober 28, 1976, the creditor shall disclose the date of each extension of credit or the date such extension of credit is debited to the account during the billing cycle, the am ount of such extension of credit and, unless previously furnished, a brief identifica tion*23*5^ of any goods or services purchased or the extension of credit. S E C T IO N 226.13— C R E D IT C A R D T R A N S A C T IO N S — S P E C IA L R E Q U IR E M E N T S * * (i) Right of cardholder to assert claims or defenses against card issuer. *** 9f Identification may be made on an accompanying slip or by symbol relating to an identification list printed on the statement. (4 ) If the cardholder refuses to pay the am ount of credit outstanding w ith respect to the property or services w hich gave rise to the claim (s) or defen se(s) under this section, the creditor m ay not rep o rt to any person th at particular am ount as delinquent until the dis pute is settled or judgm ent is ren dered .153 2. Section 2 2 6 .7 (b ) (1 ) (iii) is am ended by the deletion of the period at the end thereof and the addition of the follow ing: “ , except th at the date of crediting to th e custom er’s account need not be provided if a delay in cred iting does not result in the im position of any finance charges, late paym ent charges, or other charges for th at billing cycle o r a later billing cycle.” 15a Nothing in this paragraph prohibits a creditor from reporting the disputed amount or account as being in dispute. 5. Section 2 2 6 .7 ( b ) ( 1 ) ( ii) , as adopted by the B oard on Septem ber 15, 1975, and pub lished in the F e d e r a l R e g i s t e r on Septem ber 19, 1975 (40 F R 43200) is hereby rescinded. T h e suspension of the effective date of the tra n si tion period as adopted by the B oard on M ay 7, 1976, and published in the F e d e r a l R e g i s t e r on M ay 18, 1976 (41 F R 20395) is hereby rescinded. 3. Section 2 2 6 .7 (c )(1 ) is am ended to read as follows: * * ♦ ( 1 ) T h e inform ation required to be disclosed >K 3