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FEDERAL RESERVE BANK
OF NEW YORK

[

Circular No. 9230 ~|
January 13, 1982

REGULATIONS M and Z
Mandatory Effective Date Postponed to October 1, 1982

To All Depository Institutions in the Second
Federal Reserve District, and Others Concerned:

Following is the text of a statement by the Board of Governors of the Federal Reserve System:
The mandatory effective date of the Federal Reserve Board’s Regulation M (Consumer Leasing)
and Regulation Z (Truth in Lending), as these regulations were revised to implement the Truth in
Lending Simplification and Reform Act, has been postponed until October 1, 1982.
This will conform the Board’s regulations with an amendment to the Simplification Act, signed into
law December 26, 1981, delaying the mandatory effective date of the Simplification Act from April 1,
1982 to October 1, 1982.
Enclosed is a copy of the Board’s Order in this matter, which has been reprinted from the
Federal Register. Questions thereon may be directed to our Consumer Affairs and Bank Regulations
Department (Tel. No. 212-791-5914).




A nthony M . S o lom on,

President.

-

_

Board of Governors of the Federal Reserve System
CONSUMER LEASING — REGULATION M
TRUTH IN LENDING — REGULATION Z
Deferral of Mandatory Effective Dates
e f f e c t iv e d a t e :

12CFR Parts 213 and 226

December 31,1981.

FOR FURTHER INFORMATION CONTACT:

[Regs. M and Z; Docket No. R-03811

Consumer Leasing/Truth in Lending;
Deferral of Date for Mandatory
Compliance
a g e n c y : Board of Governors of the
Federal Reserve System.
a c t io n : Deferral of mandatory effective
dates.

The Board is deferring until
October 1,1982, the mandatory effective
date for compliance with Regulation M
(Consumer Leasing) and revised
Regulation Z (Truth in Lending), which
implement the Truth in Lending
Simplification and Reform Act. Although
the revised regulations became effective
on April 1, 1981, compliance originally
was not required until April 1; 1982. In
the interim, creditors were given a
transition period during which they
could comply with either the revised"
regulation^or the previous Regulation Z.
On December 28,198T, the President
signed into law an amendment to the
Truth in Lending Simplification and
Reform Act delaying the mandatory
effective date for six monthsuntil
October 1,1982. Pursuant to this new
statutory mandate, the Board is
deferring the mandatory effective date
for compliance with its revised
regulations and continuing the transition
period until October 1,1982.
The Board is also deferring until
October 1,1982; rescission of certain
provisions in the previous Regulation Z
(implementing the Truth in Lending Act
prior to the 1980 simplification'
amendments). The Board had permitted
creditors to comply, effective January 10,
1980, with amendments to the previous
regulation that provided greater
flexibility and protection in disclosing
the annual percentage rate and other
terms. Creditors.could, however,
continue to comply with provisions of
previous Regulation Z'until April 1,1982.
Creditors may now continue to comply
with the previous regulation until
October 1,1982.
summary:




Barbara D'. Ranagarl, Staff Attorney
(202-452-3667)', Division of Consumer
and Community Affairs, Board of
Governors o f the Federal Reserve
System, Washington, D.C. 20551.
SUPPLEMENTARY INFORMATION: (1)

Introduction. Effective April 1,1981, the
Board simplified its consumer credit
rules in Regulation Z (12 CFR Part 226)
and issued a revised regulation. The
Board also extracted the consumer
leasing rules from Regulation Z and
placed them in Regulation M (12 CFR
Part 213) (40 FR 20848, April 7, 1981).
The resulting news regulations
(hereinafter referred to as the
“simplified regulations”) reflect
amendments made by the Truth in
Lending Simplification and Reform Act
(Title VI of the Depository Institutions
Deregulation and"Monetary ControLAct
of 1980, Pub. L 96-221, 94 Stat. 170,
March 31,1980), That act had a
mandatory effective date of April 1,
1982, but permitted creditors to comply
with the simplified regulations that the
Board was required to promulgate by
April‘1 ,1981. The previous Regulation Z
(hereinafter referred to as “presimplification Regulation Z”) and
accompanying appendices, supplements
and interpretations were to remain
concurrently effective, during the
interim. By promulgating its simplified
regulations in.April of 1981, the Board
provided a 1-year transition period
during which creditors could choose to
comply with either the simplified
regulations or the pre-simplification
Regulation Z until compliance became
mandatory on April. 1,1982. The purpose
of the transition period was. to ailow
creditors sufficient time to modify their
disclosure forms and adapt their
procedures. The Official Staff
Commentary to. simplified Regulation Z
was issued on October 6,1981 (46 FR
50288, October 9,1981) giving creditors
who had waited for further clarification
slightly less: than six.months to meet the
April 1,1982, mandatary compliance
date.

On December 26,1981, the President
signed into law an amendment to the
Truth in Lending Simplification and
Reform Act delaying the mandatory
effective date for six months to October
1,1982 (Title III of the International
Banking Facility Deposit Insurance Act,
Pub. L 97-110, 95 Stat. 1513). The
deferral provides creditors and lessors
additional time to achieve compliance
and requires the-Board to delay the
mandatory compliance date of its
simplified regulations. Accordingly, the
Board is continuing the transition period
so that creditors who wish to do so may
continue to comply witn presimplification Regulation Z and
accompanying appendices, supplements,
and interpretations until October 1, 1982.
The Board is also making technical
amendments to two footnotes in
simplified Regulation Z that refer to the
mandatory compliance date by changing
the date to October 1, 1982.
The change being made is limited
strictly to the deferral of the mandatory
compliance date and does not alter the
April 1, 1981, optional compliance date.
It simply prolongs the transition period
and does not in any way affect the
substantive requirements in pre­
simplified Regulation Z, the simplified
regulations, or the transition rules
discussed in 46 FR 20848. Technical
amendments that conform the
references in the Official Staff
Commentary on Regulation Z to the
deferred mandatory compliance date
will be made when the commentary is
revised.
Five states had been granted"
exemptions from pre-simplification
Regulation Z. Those exemptions—to
Connecticut, Maine, Massachusetts,
Oklahoma, and Wyoming—were due to
expire on April'!, 1982. They will now
remain in effect until October 1, 1982,
unless superseded by a new exemption
granted under the simplified regulations.
Any state, including the exempt states,
may still seek an exemption from the
simplified regulations before that date.
The Board is also deferring until1
October T, 1982, rescission'of certain
provisions concerning the annual*

PRINTED IN NEW YORK, FROM FEDERAL REGISTER, VOL. 47, No. 4

date are neither necessary nor required
percentage rate in pre-simplification
Regulation Z. On December 31,1979; the under 5 U.S.C. 553 (b) and (d), and
immediate implementation is in the
Board amended provisions in pre­
simplification Regulation Z relating to
public interest.
the calculation and disclosure of annual
(2) Text of amendments. In
percentage rate and other credit terms
consideration of the foregoing and
(44 FR 77139). Although these
pursuant to the authority granted in
amendments Had an effective date of
section 105 of the Truth in Lending Act
January 10,1980, creditors were given
the option of complying with the new or (15 U.S.C. 1604) as amended by Pub. L.
96-221, 94 Stat. 170 (March 31,1980) and
the old provisions until October T, 1980.
Pub. L. 97-110, 95 Stat. 1513 (December
The Board subsequently changed that
26,1981), the Board amends its
date from October 1,1980, to April 1,
regulations as follows:
1982, to coincide with the mandatory
effective date of the Truth in Lending
1. The Board delays from April 1,1982,
Simplification and Reform Act (45 FR
to October 1,1982, the mandatory
56795, August 26,1980). The Board is
effective date for compliance with
now extending the optional compliance
simplified Regulations Z and M and the
period until October 1,1982. to coincide
expiration of pre-simplification
with the deferred effective date of:the
Regulation Z (12 CFR Part 226),
Truth in Lending Simplification and
appendices, supplements, Board and
Reform Act.
staff interpretations, and state
The actions being taken are required
exemptions. The April 1,1981, effective
by Pub. L. 97-110 enacted December 26;
date for optional compliance with
1981. These actions facilitate
simplified Regulations Z and M as
implementation of the 1980
described in 46 FR 20848 (April 7.1981)
simplification act and do not impose any remains unchanged.
additional burden or liability. Therefore,
2. The Board amends simplified
publication of the changes for public
Regulation Z (12 CFR Part 226) as
comment and a delay in their effective




described in 46 FR 20848 (April 7,1981)
by changing the date in footnote 31a to
§ 226.14 and footnote 45a to $ 226.22
from “April 1,1982,” to “October 1,
1982.”
3.
The Board delays from April 1,1982,
to October 1,1982, rescission of § 226.5
(b) through (e), Board Interpretations
§§ 226.502. 226.503 and 226.505, and
Supplement I to pre-simplification
Regulation Z (12 CFR Part 226), as
described at 44 FR 77139 (December 31,
1979) and 45 FR 56795 (August 26,1980).
The January 10,1980, effective date for
revisions to § 226.5 and Supplement I,
and new § 226.8 (r) and (s) remains
unchanged.
(3) Authority. Sec. 105 of the Truth in
Lending Act as amended by section 605,
Pub. L. 96-221, 94 Stat. 170 (15 U.S.C.
1604). Board of Governors of the Federal
Reserve System, acting by the Secretary
of the Board pursuant to delegated
authority under 12 CFR 265.2(a),
December 31.1981.
William W. Wiles,

Secretary of the Board.