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regulatory opacity October 29, 2010

Posted by Bradley in : consultation , trackback

The Federal Reserve’s final rule on gift cards and the Credit Card Act was published in the Federal Register today. The rule states:

The Board received two comments on the interim final rule from a credit union trade association and a bankers’ trade association. Both commenters generally supported the interim final rule. The bankers’ trade association suggested that the Board exercise its exception authority to eliminate in-store disclosures where cards sold meet the final gift card rule’s substantive fee and expiration date protections. This commenter also requested an extension of the delayed effective date. No other comments were received. The final rule adopts the interim final rule as issued, with minor non-substantive edits.

The comments don’t seem to have been that significant and didn’t seem to have an effect on what the Fed did, but still, and in the spirit of transparency reflected, for example at regulations.gov, I’d like to know who these commenters were, and exactly what they said. The NAFCU’s website shows that it sent comments to the Fed dated April 14, 2010 on ” The CARD Act Final Two Provisions” although these comments are only accessible by members. Other comments by the NAFCU to agencies which publish responses,such as the SEC, (the Fed does publish responses to some of its proposals) are visible.


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