Regulation Z - Truth in Lending
December 15, 1997
Circular No. 11007

Proposed Revisions to Official Staff Commentary

Comment Requested by January 20, 1998

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

The following is from a statement by the Board of Governors of the Federal Reserve System:

The Federal Reserve Board has published proposed revisions to the official staff commentary to Regulation Z, Truth in Lending, which applies and interprets the requirements of the regulation. Comment is requested by January 20, 1998.

The proposed revisions address:

  • increased rates for credit card accounts caused by late payments or exceeding credit limits;
  • guidance on "same-as-cash" transactions in open-end plans; and
  • guidance for determining whether credit is an open-end plan or a closed-end transaction.

In addition, the proposed update to the commentary discusses issues such as the treatment of annuity costs in reverse mortgage transactions and transaction fees imposed on checking accounts with overdraft protection.

The Board's proposal, as published in the file (pdf - 131kb). Comments should be sent to the Board, as specified in the notice, by January 20, 1998.