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Testimony of Governor Edward M. Gramlich
Regulation Z (Truth in Lending Act)
Before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate
May 17, 2005
Chairman Shelby, Senator Sarbanes, and members of the Committee, I appreciate the
opportunity to appear today to discuss consumer credit card accounts. The Board of
Governors of the Federal Reserve System administers the Truth in Lending Act (TILA).
Enacted in 1968, TILA is the primary federal law governing disclosures for consumer credit,
including credit card accounts. It is implemented in the Board's Regulation Z.
TILA has distinct rules for two categories of consumer credit: open-end (revolving) credit
plans, such as credit card accounts and other lines of credit; and closed-end (installment)
transactions, such as auto loans and home-purchase loans. Amendments targeting specific
loan products or practices have been added over TILA's nearly forty-year history and the act
was substantially revised by the Truth in Lending Simplification and Reform Act of 1980.
TILA's purpose is to assure a meaningful disclosure of credit terms so that consumers can
compare more readily the various credit terms available and avoid the uninformed use of
credit. TILA fulfills this purpose by requiring the uniform disclosure of costs and other
terms to consumers. TILA is also intended to protect consumers against inaccurate and
unfair credit billing and credit card practices, which the act seeks to accomplish through
procedural and substantive protections, including special rules for cardholders.
Regulation Z review. Regulation Z and its staff commentary have been reviewed and
updated almost continuously, but not comprehensively since 1980. In December 2004, the
Board began a comprehensive review of Regulation Z, starting with the publication of an
advance notice of proposed rulemaking (ANPR) on the rules for open-end credit that is not
home-secured, such as general-purpose credit cards.1 The goal of the review is to improve
the effectiveness and usefulness of open-end disclosures and substantive protections. The
public comment period recently closed, and the Board's staff will be carefully reviewing the
comment letters as they consider possible changes to the regulations. We also believe that
consumer testing should be used to test the effectiveness of any proposed revisions, and
anticipate publishing proposed revisions to Regulation Z in 2006.
We recognize the hard work that is ahead. The landscape of credit card lending has changed
since TILA's disclosure rules for credit card accounts were first put in place. Products and
pricing are complex. Credit card accounts can be used for purchases, cash advances, and
balance transfers, and each means of access may carry different rates. Promotional rates and
deferred interest plans for limited time periods are commonly layered onto these basic
features. However, under some credit card agreements, paying late or exceeding a credit
limit may trigger significant fees and a penalty rate that is applied to the entire outstanding
balance, and may trigger higher rates on other credit card accounts. Moreover, the amount of
consumers' payments, how creditors allocate those payments to outstanding balances, and
how the balances are calculated all affect consumers' overall cost of credit under open-end
plans.
The question is, of course, how might the Board revise its rules under TILA in a way that
will enable consumers to more effectively use disclosures about the key financial elements
of a particular credit card over the life of the account? Simplifying the content of disclosures
may be one way; finding ways to enhance consumers' ability to notice and understand
disclosures may be another. Reviewing the adequacy of TILA's substantive protections is a
third, and the ANPR asks questions about each of these areas. As the Regulation Z review
proceeds, the Board will be grappling with the challenge of issuing clear and simple rules
for creditors that both provide consumers with key information about complicated products
(while avoiding so-called "information overload") and provide consumers adequate
substantive protections, consistent with TILA. For example, TILA contains procedures for
resolving billing errors on open-end accounts, prohibits the unsolicited issuance of credit
cards, and limits consumers' liability when a credit card is lost or stolen.
To assist the Committee in its deliberations, I will provide an overview of TILA's rules
affecting open-end credit plans, focusing on rules for credit card accounts. I will discuss
some of the major issues raised in the ANPR, and commenters' views on these issues. I will
also address compliance and enforcement issues, along with the role of consumer education
in improving consumers' informed use of credit.
Disclosures for Open-end Credit Plans
TILA disclosures for open-end plans are provided to consumers:
z
z
z
On or with credit card applications and solicitations, such as applications sent by
direct mail.
At account opening.
Throughout the account relationship, such as on periodic statements of account
activity and when the account terms change.
Content. Generally, the disclosures provided with credit card applications, at accountopening and on periodic statements, address the same aspects of the plan; that is, in each
case consumers receive information about rates, fees, and grace periods to pay balances
without incurring finance charges. The level of detail differs, however.
Disclosures received with a direct-mail credit card account application are intended to
provide a snapshot to help the consumer decide whether or not to apply for the credit card
account. For example, revolving open-end accounts involve calculating a balance against
which a rate is applied. The method for calculating that balance may differ from creditor to
creditor, however. Under TILA, identifying a balance calculation method by title, such as
the "average daily balance method (including new purchases)," is sufficient at application.
Account-opening disclosures are more detailed and complex, however, in part because the
account-opening disclosures required under TILA are typically incorporated into the
account agreement. The periodic statement discloses information specific to the statement
cycle. In the case of balance calculation methods, the disclosure is typically identical to the
account-opening disclosure.
Creditors must also tell consumers about their rights and responsibilities under the Fair
Credit Billing Act, a 1974 amendment to TILA that I will discuss later, which governs the
process for resolving billing disputes. In addition to explaining these rights in the accountopening disclosures, creditors must send reminders throughout the account relationship.
Under TILA, a detailed explanation must be sent about once a year; typically, however,
creditors instead send an abbreviated reminder on the reverse side of each periodic
statement, as permitted by Regulation Z.
Format. Generally, disclosures must be in writing and presented in a "clear and
conspicuous" manner. For credit card application disclosures, the "clear and conspicuous"
standard is interpreted to mean that application disclosures must be "readily noticeable."
Disclosures that are printed in a twelve-point type size have a safe harbor in the regulation
under this standard.
Disclosures for direct-mail credit card account applications have the most regimented format
requirements. The disclosures must be presented in a table with headings substantially
similar to those published in the Board's model forms. Regulation Z's sole type-size
requirement also applies to direct-mail application disclosures; the annual percentage rate
for purchases must be in at least eighteen-point type size. Format requirements for credit
card account applications available to the general public ("take-one's") are quite flexible. At
the card issuer's option, take-one disclosures may be in the form required for direct-mail
applications, an abbreviated narrative, or a simple statement that costs are involved that
provides information about where details can be obtained.
Compared to application disclosures, account-opening and periodic statement disclosures
are governed by few specific format requirements. Except in the context of recently enacted
amendments to TILA contained in the Bankruptcy Abuse Prevention and Consumer
Protection Act of 2005 ("2005 Bankruptcy Act"), disclosures need not be presented in any
particular order, nor is there any detailed guidance on the "clear and conspicuous" standard
other than a requirement that the terms "finance charge" and "annual percentage rate" must
be more conspicuous than any other term.
The 2005 Bankruptcy Act contains several amendments to TILA, three of which are
particularly relevant here. The act generally requires creditors to provide on the front page
of periodic statements a warning about the effects of making minimum payments and a
standardized example of the time it would take to pay off an assumed balance if the
consumer makes only the minimum payment, along with a toll-free telephone number that
consumers can use to obtain estimates of how long it would take to pay off their actual
account balance. In addition, the act provides that if a temporary rate is offered on
solicitations and applications, or promotional materials that accompany them, the term
"introductory" must be "immediately proximate" to each listing of the temporary rate. The
expiration date and the rate that will apply when the introductory rate expires must be
"closely proximate" to the first listing of the introductory rate in promotional materials.
Under the act, the Board must issue guidance regarding a "clear and conspicuous" standard
applicable only to these minimum payment and introductory rate disclosures, including
model disclosures.
The Board has published model forms and clauses to ease compliance for many of TILA's
disclosure requirements. Creditors are not required to use these forms or clauses, but
creditors that use them properly are deemed to be in compliance with the regulation
regarding these disclosures. The Board has published model forms for direct-mail credit
card account application disclosures, but there are no model forms illustrating account-
opening or periodic statement disclosures.
Regulation Z review. Considering how consumers' use of open-end credit, and credit cards
in particular, has grown, and the increased diversity in credit products and pricing, the
Board's ANPR asked a number of detailed questions about how to improve the effectiveness
and usefulness of TILA's open-end disclosures, including how to address concerns about
"information overload." The Board also invited comment on how the format of disclosures
might be improved, and whether additional model disclosures would be helpful. The Board
announced its intent to use focus groups and other research to test the effectiveness of any
new disclosures.
In general, commenters representing both consumers and industry believe that the
regimented format requirements for TILA's credit card account application disclosures have
proven useful to consumers, although a variety of suggestions were made to add or delete
specific disclosure requirements. Many, however, noted that typical account-opening
disclosures are lengthy and complex, and suggested that the effectiveness of accountopening disclosures could be improved if key terms were summarized in a standardized
format, perhaps in the same format as TILA's direct-mail application disclosure. These
suggestions are consistent with the views of some members of the Board's Consumer
Advisory Council, who advise the Board on consumer financial services matters. Industry
commenters support the Board's intention to use focus groups or other consumer research
tools to test the effectiveness of any proposed revisions.
To combat "information overload," many commenters asked the Board to emphasize only
the most important information that consumers need at the time the disclosure is given. They
asked the Board to avoid rules that require the repetitive delivery of complex information,
not all of which is essential to comparison shopping for credit cards, such as a lengthy
explanation of the creditor's method of calculating balances that is now required at accountopening and on periodic statements. Commenters suggested that the Board would more
effectively promote comparison shopping by focusing on essential terms in a simplified
way. They believe some information could also be provided to consumers through
educational, non-regulatory methods. Taken together, this approach could lead to simpler
disclosures that consumers might be more inclined to read and understand.
Truth in Lending's Cost Disclosures for Open-end Credit Plans
As I have indicated, TILA is designed to provide consumers with information about the
costs and terms of a particular form of credit, to enable consumers to make comparisons
among creditors or different credit programs, or to determine whether they should obtain
credit at all.
Finance charges and other charges. Creditors offering open-end credit must disclose fees
that are "finance charges" and "other charges" that are part of the credit plan. A "finance
charge" is broadly defined as any charge payable directly or indirectly by the consumer and
imposed directly or indirectly by the creditor, as an incident to or a condition of the
extension of credit. Interest, cash advance fees, and balance transfer fees are examples of
finance charges. Fees that are not incident to the extension of credit, but are significant
charges imposed as part of an open-end plan must also be disclosed as "other charges." Late
payment fees, application fees, and recurring periodic membership fees that are payable
whether or not the consumer uses the credit plan ("annual fees") are examples of other
charges.
Annual percentage rate. Under TILA, the finance charge is also expressed as an annualized
rate, called the Annual Percentage Rate, or APR. Interestingly, within the Truth in Lending
structure, the term represents three distinct calculations, one under TILA's rules for closedend credit and two under the rules for open-end credit.
For closed-end (installment) credit, the APR includes interest and finance charges other than
interest, such as points or origination fees on mortgage loans. Thus, the APR on closed-end
transactions can be somewhat higher than the interest rate identified in the loan agreement,
whenever other fees are present in the finance charge.
APRs for open-end credit are calculated differently. Interest is the only component of the
APR that can be disclosed on credit card solicitations and applications, account-opening
disclosures, and advertisements for open-end plans. This is because the actual cost of credit
to the consumer is unknown when these disclosures are provided, since the amount and
timing of advances and the imposition of fees generally are in the consumer's control.
Periodic statements must also disclose an "effective" or "historic" APR that reflects interest
as well as finance charges other than interest, such as a cash advance fee, that were imposed
during the past billing cycle. Because non-interest finance charges are amortized over one
billing cycle for purposes of disclosing the effective APR, such fees can result in a high,
double-digit (or sometimes triple-digit) effective APR on periodic statements. To avoid a
skewed APR that could possibly mislead consumers, non-recurring loan fees, points, or
similar finance charges related to the opening, renewing, or continuing of an open-end
account are currently excluded from the effective APR that is disclosed for a particular
billing cycle, under Regulation Z and the Board's official staff commentary.
Regulation Z Review. A major focus of the Board's Regulation Z review is how to disclose
more effectively the cost of open-end credit. For the industry as a whole, the types of fees
charged on open-end consumer credit accounts have grown in number and variety. To the
extent these fees are not specifically addressed in TILA or Regulation Z, creditors are
sometimes unsure whether the fee should be disclosed under TILA as a "finance charge" or
an "other charge," or not disclosed under TILA at all. The Board asked for comment in the
ANPR on how to provide more certainty in classifying fees, and whether consumers would
benefit from other disclosures that address the cost of credit, such as how creditors allocate
payments.
Commenters provided a variety of views. Some suggested that creditors should disclose
only interest as the "finance charge" and simply identify all other fees and charges. Others
suggested that all fees associated with an open-end plan should be disclosed as the "finance
charge." Above all, to mitigate the risks and potential liability for non-compliance, creditors
seek clear rules that allow them to classify, with confidence, fees as a "finance charge" or an
"other charge" under TILA, or as fees that are disclosed pursuant to the credit agreement or
state law. Under the statute, a creditor's failure to comply with TILA could trigger a private
right of action by consumers and administrative sanctions by the federal agency designated
in TILA to enforce its provisions with regard to that creditor.
One of the Board's most difficult challenges in the Regulation Z review is to address the
adequacy of periodic statement APRs. TILA mandates the disclosure of the effective APR
on periodic statements, but its utility has been controversial. Consumer advocates believe it
is a key disclosure that is helpful, and provides "shock value" to consumers when fees cause
the APR to spike for the billing cycle. Commenters representing industry argued that the
effective APR is not meaningful, confuses consumers, and is difficult to explain. They said
the disclosure distorts the true cost of credit because fees are amortized over one billing
cycle--typically thirty days--when the credit may be repaid over several months. Several
commenters urged the Board to include in the effective APR calculation only charges that
are based on the amount and duration of credit (interest). In response to the Board's ANPR,
some commenters believe the effective APR might be more effectively understood if a
disclosure on the periodic statement provided additional context.
Comments received on the merits of requiring creditors to disclose payment allocation
methods illustrate the competing interests in improving the overall effectiveness of cost
disclosures. Some commenters believe any additional disclosure about payment allocation
methods would be excessive and that many card issuers already make such disclosures.
Others believe such a disclosure could be helpful to consumers but worry that descriptions
might be overly detailed; some asked the Board to publish model disclosures to ensure
clarity and uniformity.
Rate increases. Credit card account agreements typically allow card issuers to change
interest rates and other fees during the life of the account. Agreements spell out with
specificity some potential changes, such as that the rate will increase if the consumer pays
late. Credit card agreements also more generally reserve the right to increase rates, fees, or
other terms.
The statute does not address changes in terms to open-end plans. Regulation Z, however,
requires additional disclosures for some changes. The general rule is that fifteen days'
advance notice is required to increase the interest rate (or other finance charge) or an annual
fee. However, advance notice is not required in all cases. A notice is required, but not in
advance, if the interest rate increases due to a consumer's default or delinquency. And if the
creditor specifies in advance the circumstances under which an increase to the finance
charge or an annual fee will occur, no change-in-terms notice is required when those
circumstances are met before the change is made. This is the case, for example, when the
agreement specifies that the interest rate will increase if the consumer pays late. Under
Regulation Z, because the card issuer has specified when rates will increase in the account
agreement, the creditor need not provide advance notice of the rate increase; the new rate
will appear on the periodic statement for the cycle in which the increase occurs.
Regulation Z review. The ANPR asked how consumers were informed about rate increases
or other changed terms to credit card accounts, and whether the current rules were adequate
to allow consumers to make timely decisions about how to manage their accounts.
Comments were sharply divided on this issue. Some consumers believe there is not enough
advance notice for changes in terms, and believe a much longer time period is needed to find
alternative credit sources. Creditors generally believe the current rules are adequate. The
fifteen days' advance notice is sufficient, they stated, because change-in-term notices are
typically sent with periodic statements, which means as a practical matter consumers receive
about a month's notice before the new term becomes effective. Creditors noted that many
states require at least thirty days' advance notice and allow consumers to "opt-out" of the
new terms by closing the account and paying the outstanding balance under the former
terms. For rate (and other) changes not involving a consumer's default, a number of creditors
support a thirty-day notice rule and a few support a consumer "opt-out" right under
Regulation Z.
Where triggering events are set forth in the account agreement, creditors believe there is no
need to provide additional notice when the event occurs; they are not changing a term, they
stated, but merely enforcing the agreement. Some suggested this is a case where consumer
education is the best solution, and that perhaps Board-published model forms would result
in uniformity and greater consumer understanding. Consumers and consumer groups agreed
that change-in-term policies should be more prominently displayed, including in the credit
card application disclosures.
Procedures and Substantive Protections
TILA and Regulation Z provide protections to consumers when a lost or stolen credit card is
used ("unauthorized use"), when the consumer believes a charge on a billing statement is in
error ("billing error"), and when a purchase is made with a credit card and the consumer
cannot resolve with the merchant honoring the card a dispute about the quality of goods or
services ("claim or defense"). The Fair Credit Billing Act was enacted, in part, to provide a
procedure for resolving disputes between cardholders and merchants who honor credit
cards, and to allocate to card issuers some responsibility for providing relief to the consumer
if the merchant fails to accommodate the cardholder.
In general, these protections allow the consumer to avoid paying the disputed amount while
the card issuer investigates the matter. The card issuer cannot assess any finance charge on
the disputed amount or report the amount as delinquent until the investigation is completed.
Depending on the facts, a dispute could trigger one or more of the protections discussed
below. The applicability of a protection can hinge on timing (when the cardholder notifies
the card issuer about the problem), the outstanding balance (how much of the sale price
remains unpaid at the time the cardholder notifies the card issuer), and receipt of the good or
services (nothing was delivered, or something was delivered but didn't meet the cardholder's
expectations).
Unauthorized use of a credit card. A cardholder cannot be held liable for more than $50 for
the unauthorized use of a card. State law or other applicable law determines whether the
cardholder "authorized" the use of the card. There are no specific timing or procedural
requirements to trigger this protection (other than notifying the card issuer). An
unauthorized charge may also be raised as a billing error or a claim or defense.
Billing error. The billing error provisions contain the strictest timing and procedural
requirements of TILA's substantive protections for open-end plans. For example, the
consumer's claim must be in writing and sent to the address specifically designated for this
purpose. The consumer triggers the billing error rules by notifying the creditor about the
dispute. The notice must be received, and creditors must respond, within a set time period. If
asserted in a timely manner, a billing error can be asserted even if the consumer previously
paid the charge in full.
Claim or defense for a credit card purchase. Cardholders may assert against the card issuer
any claim or defense they could assert against the merchant. Cardholders trigger the rule by
notifying the card issuer that they have been unable to resolve a dispute with a merchant
about a sales transaction where a credit card was used. There is no specific time period
within which the cardholder must give notice or the card issuer must respond. However, the
cardholder must try to resolve the matter with the merchant before involving the card issuer.
Unlike the billing error provision, this remedy is available only if the cardholder has an
unpaid balance on the disputed purchase at the time notice is given.
Under TILA, the claim or defense remedy cannot be used to assert tort claims (for example,
product liability) against the card issuer. Also, the remedy is available only for sales
exceeding $50 and for sales that occur in the state the cardholder has designated as his
address or within 100 miles of that address.
Unsolicited issuance. Credit cards may be issued to consumers only upon request.
Nevertheless, credit cards may be issued to cardholders in renewal of, or substitution for, a
previously accepted card (including supplemental cards for the existing account).
Regulation Z Review. The Board's ANPR asked whether there was a need to revise the
regulations' provisions implementing TILA's substantive protections, for example, whether
the rules need to be updated to address particular types of accounts or practices or to address
technological changes. To illustrate, TILA requires creditors to credit payments on open-end
plans on the day the payment is received. Regulation Z permits creditors to set reasonable
cut-off hours, which must be disclosed to consumers. The ANPR solicited comment on
payment process systems, where mail delivery and electronic payments may be continuous
twenty-four hours a day, seven days a week, and whether further guidance was needed on
what constitutes a "reasonable" cut-off hour.
Most industry commenters stated that cut-off hours vary among creditors due to a number of
internal and external factors, and asked that creditors' flexibility in processing payments be
maintained. The Board also received suggestions for standardizing cut-off hours in ranges,
such as between 3 p.m. and 5 p.m. for mail delivery and 6 p.m. and 8 p.m. for electronic
payments.
Consumers and some consumer groups suggested that payments be credited as of the date
payments are received regardless of the time. They asked the Board to consider rules that
would provide greater certainty to consumers with regard to determining when the payment
is received, because creditors more frequently than in the past exercise their right under the
account agreement to impose late fees when a payment is not received by the due date.
Moreover, consumer groups stated, many credit card agreements allow creditors to increase
rates when the creditor learns the cardholder was late on another account even if the
cardholder makes timely payments to the creditor.
Supervision and Enforcement
As part of the bank supervision process, the Federal Reserve enforces safe and sound
banking practices and compliance with federal banking laws, including the Truth in Lending
rules, with respect to the approximately 915 state-chartered banks that are members of the
Federal Reserve System. Other regulators enforce these rules with respect to other
institutions. For the vast majority of state member banks, credit card lending is not a
significant activity. In fact, of the banks supervised by the Federal Reserve, the issuance of
credit cards is the principal business activity of only two of these banks.
In January 2003, the Federal Reserve, along with the Office of the Comptroller of the
Currency, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision,
issued interagency guidance on credit card account management practices. Federal Reserve
supervisory staff have applied the principles of this guidance through constructive
discussions with bank management about individual institutions' portfolio management
practices. In the limited instances where formal or informal enforcement actions have
proven necessary to ensure sound management of an institution's credit card portfolio, the
Federal Reserve has appropriately exercised this authority.
The Board also investigates consumer complaints against state member banks and forwards
complaints it receives involving other creditors to the appropriate enforcement agencies. In
2004, the Board received approximately 5,100 consumer complaints. Of this number,
approximately 2,300, or 45 percent, were against state member banks, while about 2,800, or
55 percent, were against other creditors not under the Board's supervisory authority and
were forwarded to the appropriate agencies.
About 39 percent of the 2,300 complaints against state member banks processed by the
Board were complaints about credit cards. The data show that complainants' main concerns
were about interest rates and terms, penalty charges and fees such as late fees, over-the-limit
fees, and annual fees. In addition, consumers were concerned that their credit information
was incorrectly reported to consumer reporting agencies. By way of comparison, industry
estimates suggest there are more than 600 million credit cards in consumers' hands and
annual domestic transactions involving credit cards exceed $1 trillion.
Role for Consumer Financial Education
This detailed description of the issues of concern in our review of Regulation Z is
illustrative of both the complexity of and the growth in today's consumer credit markets.
Technology has significantly changed consumers' payment options, with the credit card
becoming an accepted payment medium for virtually any consumer good or service. In
addition, credit scoring models, the mathematical formulations lenders use to predict credit
risk, have enabled creditors to price credit more efficiently, and charge rates of interest
commensurate with a consumer's repayment risk. This technology has contributed to the
expansion of the subprime market, which has significantly increased access to credit for
consumers who, more than likely, would have been denied credit in the past.
As a result, concerns surrounding consumer protection relate as much to issues of fair
pricing practices as they do to fair access to credit. In addition, as the industry has become
more competitive on interest rate pricing, it has adopted more complex fee structures that, if
triggered, affect a consumer's overall cost associated with the credit card.
The use of disclosure rules as a consumer protection strategy is predicated on the
assumption that consumers have an understanding of consumer credit and personal financial
management principles. By dictating disclosure requirements, regulators and lawmakers rely
on consumers to be familiar with basic financial principles and to be able to evaluate
personal financial scenarios and options, once they have access to pertinent financial
information. Indeed, this is the fundamental premise of our free market system, in which
information increases market efficiency. In recent years, however, there has been an
increase in concern that consumers' level of financial literacy has not kept pace with the
increasingly complex consumer financial marketplace and the expansion of financial service
providers and products.
Lenders, regulators, and consumer and community advocacy groups have agreed that there
is an increased need for consumer financial education, and have pointed to a variety of
factors, including record personal bankruptcy filings, high consumer debt levels, and low
personal savings rates, to support this assertion. Financial education could encourage
consumers to focus on their credit contracts in addition to the TILA disclosures, which
highlight the key terms of the contract. Toward this end, many public and private initiatives
have been undertaken at both the local and national level to highlight the importance of
financial education.
As you know, Congress has established the Financial Literacy and Education Commission
and the Financial and Economic Literacy Caucus--further demonstration of the degree of
interest and concern in helping consumers obtain the knowledge they need to effectively
manage their personal finances. The Federal Reserve System has also been active in
promoting consumer financial education, and is an active participant in initiatives to further
policy, research, and collaboration in this area.
In closing, I would like to note that disclosure and financial education work in tandem in the
interest of consumer protection, and I believe that it is important to continue to focus our
collective attention on both fronts.
Footnotes
1. The Board's advance notice of proposed rulemaking for Regulation Z. Return to text
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