Michigan Bankers Association
March 29, 2004
Office of the Comptroller
of the Currency – Docket #03-10
Board of Governors of the Federal Reserve System – Docket #R-1151
Federal Deposit Insurance Corporation – 12 CFR, Ch. III
Office of Thrift Supervision - #2003-02
Via: http://www.EGRPRA.gov
Re: Lending-Related Rules; Economic Growth and Regulatory Paperwork
Reduction Act of 1996 Review
Dear Regulators:
The Michigan Bankers Association (MBA) represents over 190 commercial
banks and thrifts in the state of Michigan. We welcome the opportunity
to comment on the proposal to amend the various regulations pertaining
to the Economic Growth and Regulatory Paperwork Reduction Act of
1996.
The proposal would amend
Regulation E to add a definition of “clear
and conspicuous” that would be consistent with the definition
contained in Regulation P, Privacy of Customer Financial Information.
Currently, Regulation E provides that disclosures must be “clear
and readily understandable.” Regulation P currently defines
the “clear and conspicuous” standard to mean that the
disclosure is “reasonably understandable and designed to call
attention to the nature and significance of the information.” The
Regulators believe that the recently implemented standard in Regulation
P is a more precise explanation of the concepts underlying the duty
to provide disclosures that consumers will notice and understand.
Overall, the MBA supports reduction of regulatory burden on insured
depository institutions and we also support ensuring that the disclosures
are as clear and understandable as possible for consumers. However
we are opposed to these proposals. We do not believe they meet the
goals established in issuing the proposals. These proposals would
not ensure that consumers receive noticeable and understandable information
that is required in connection with obtaining consumer financial
products and services.
We would like to urge the withdrawal of these proposals. The review
and various required changes to current forms would create tremendous
costs to our financial institutions. The MBA does not believe the
benefit of implementing the proposed changes outweigh the burden
of financial and human resources.
The MBA appreciates the opportunity to comment on this very important
matter. If you have any questions regarding this letter, please contact
the MBA at (517) 485-3600 or tgreisinger@mibankers.com.
Sincerely,
Terry G. Greisinger
Vice President, Government Affairs
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