Comments of the
National Consumer Law Center
(On behalf of its Low-Income Clients)
and
Consumers Union
U.S. Public Interest Research Group
Regarding
Advance Notice of Proposed Rulemaking
Implementation of the Bankruptcy Act Amendments
To Truth in Lending
Federal Reserve System
12 CFR Part 226
Docket No. R-1217

These comments are submitted by the National Consumer Law Center (on behalf of its low income clients),1 Consumers Union,2 and U.S. Public Interest Research Group3 concerning the Federal Reserve Board’s advance notice of proposed rulemaking to implement the amendments of the 2005 Bankruptcy Act to the Truth in Lending Act4 (“2005 Amendments).

These 2005 Amendments impose a number of new disclosure requirements on creditors regarding minimum payments, teaser rates, Internet solicitations and applications, and late payment fees. Our comments focus on the questions the payment disclosures (Section I), introductory rate disclosures payments (Section III), Internet disclosures (Section IV), that exceed the home’s fair market value (Section V).