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Fof release on delivery
Statement of J. L. Robertson, Vice Chairman
Board of Governors of the Federal Reserve System
before the
Senate Banking and Currency Committee
Subcommittee on Financial Institutions

May 19, 1969

If we had a Truth in Testifying law, I would have to confess
that I am not really delighted to be here this morning.

I find myself

in the awkward position of having little to contribute to this hearing.
The Board of Governors of the Federal Reserve System believes, as I
suppose everyone here does, that credit information on individuals
should be accurate, and that credit reporting agencies should conduct
their operations "with fairness, impartiality, and a respect for the
individual right to privacy," as provided in S. 823.

But the Board

is not in a position to help you decide whether Federal legislation is
needed or useful in achieving this goal or to recommend the kind of
legislation that would be most appropriate if a need exists.
Service as a member of the Board does not equip one to
decide whether a Federal law is the answer to the very serious
questions raised by S. 323.

In carrying out our responsibilities,

we have virtually no contact with the credit reporting agencies that
would be regulated under the bill, and we would not presume to advise
you regarding what may be right or wrong about their existing
procedures, or for that matter what their procedures are, since you
unquestionably know more about them than we do.




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While the Board has no position, therefore, on the merits
of the bill,, we do have a recommendation as to its administrative
provisions. As introduced, S. 823 would direct the Board to prescribe
implementing regulations.
prepared to assume.

This is a responsibility the Board is not

The functions vested in the Board by the Truth

in Lending Act should not be taken as a precedent for assigning to
the Board wide-ranging duties in the general area of consumer
protection.

Such an assignment would be inconsistent with effective

performance of our primary duties in the field of monetary policy.
In view of the increasing interest Congress is showing in expanding
Federal legislation for the protection of consumers, we strongly
recommend that responsibility for implementing such legislation be
vested not in the Board but in an agency more familiar with consumer
problems and more expert in coping with them.