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Dreher Tomkies LLP
Attorneys at Law
2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
Telephone: 614-628-8000
Fax: 614-628-1600

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The Federal Reserve Board (Board), the Office of Thrift Supervision and the National Credit Union Administration recently proposed rules clarifying certain aspects of their December 2008 final rules under the Federal Trade Commission Act prohibiting certain unfair and deceptive acts and practices (UDAP) with respect to credit cards. See 74 Fed. Reg. 5498 (Jan. 29, 2009). The Board also proposed clarifications to its December 2008 final rule under the Truth in Lending Act (TILA) amending Regulation Z. See 74 Fed. Reg. 5244 (Jan. 29, 2009). See Alert dated April 22, 2009.

Among other things, the proposed clarifications would permit creditors to continue to offer “deferred interest” promotional plans. If H.R. 627 (Apr. 30, 2009) is enacted, certain provisions of the Truth in Lending Act would be amended consistent with some of the proposed clarifications. See Alert dated May 4, 2009.

The agencies seek comment on certain discrete issues within 30 days of publication in the Federal Register, which occurred on May 5, 2009. See 74 Fed. Reg. 20804 (May 5, 2009) (proposed UDAP clarifications) and 74 Fed. Reg. 20784 (May 5, 2009) (proposed Regulation Z clarifications). Thus, the deadline for comments is June 4, 2009.

  • Judy Scheiderer