By Alan Lavine and Gail Liberman
Disgruntled credit-card holders of the world, unite. Finally, an opportunity to exercise our democratic rights and change some sleazy credit card practices! The Federal Reserve Board of Governors seeks comments by March 28 for a proposed review of its revolving credit rules under "Regulation Z," which implements the Truth in Lending Act. "The Federal Reserve Board rarely gets comments on proposed changes to Reg Z directly from consumers," said Elizabeth Renuart, attorney for the National Consumer Law Center, Boston. This marks a great opportunity for the board to hear "the raw voices of consumers' discontent." Best to wait to file your comments until the March 28 deadline. Reason: The Federal Reserve posts comments online at least every two weeks. Why give the banking industry more time to refute your arguments?
To be most effective, Renuart suggests that you "highlight what's not clear about disclosures received." If you have a complaint about how you're being treated by a creditor, feel free to mention it in your letter. But it's probably not something the Fed will address in these regulations.
Warning: The Federal Reserve Board of Governors lacks authority to do much about some of your other complaints. However, after you've commented on the disclosure issues that irk you, it doesn't hurt to rant about all the things you've been e-mailing us about. The Fed has a consumer complaint division to which it may refer those issues.
Angry about the practice of a specific bank? Notify the Office of the Comptroller of the Currency. Contact the customer assistance department, which you can do online at www.occ.treas.gov, Renuart suggests. Don't expect the comptroller to do much. But if the agency gets enough complaints about a single bank from enough people, there's a remote chance it could act. Renuart initially cites these issues that could be worth changing as it relates to credit cards:
- All credit card solicitations currently must contain a table known as a "Schumer Box," abbreviating highlights of the terms of your agreement -- including rates and fees. Problem: When you finally get your credit card you never see that box again. Renuart suggests that you ask the Fed to require the Schumer Box on your final card agreement, so that you can compare.
- Suggest clarification of "change in notice" terms. Perhaps the Fed can require that the card issuer clearly show pricing "before" the change as well as "after" in an abbreviated format. Also, you might wish to suggest that a change in terms come as a separate mailing.
The Truth in Lending Act provides us with some great consumer rights, including:
- Limitation of your liability if a credit card is lost or stolen to $50.
- Your right to assert a billing error, triggering the creditors' duty to investigate the allegation within prescribed time limits.
- Your right to possibly avoid paying a charge if a merchant honoring the card fails to resolve a dispute about the quality of goods or services.
To change these rights would require an act of Congress. Want more consumer rights with your credit card? It never hurts to tell the Fed, "By the way, we'd also like these additional rights," she said.
Be sure to e-mail your comments, identified by Docket No. R-1217 in the subject line of your message, to regs.comments@federalreserve.gov. You also may fax the comments to 202-452-3102, or mail them to Jennifer J. Johnson, secretary, Board of Governors of the Federal Reserve System, 20th Street and Constitution Avenue, N.W., Washington, DC 20551.
(Spouses Alan Lavine and Gail Liberman are syndicated columnists. Contact them at mwliblav@aol.com)
