WASHINGTON — CUNA and NAFCU commended the Federal Reserve Board for proposing to withdraw unnecessary e-commerce regulations.
The rules to be withdrawn cover how electronic disclosures can be provided by credit unions and others as required under Regulation B (the Equal Credit Opportunity Act), Regulation E (the Electronic Fund Transfer Act), Regulation M (the Consumer Leasing Act), Regulation Z (the Truth in Lending Act), and Regulation DD (the Truth in Savings Act).
CUNA's letter stated, "We agree that for applications and solicitations that are accessed electronically, consumer consent should not be required before providing the disclosures that accompany these applications and solicitations." It also said that CUNA appreciates the forward thinking of the proposal.
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NAFCU, too, generally supported the proposal. The group did as for a clarification regarding variable Annual Percentage Rates. "NAFCU understands the proposed provision to state that a variable APR is accurate if it was in effect within the previous 30 days (if in electronic form) or 60 days (direct mail)," Senior Vice President for Government Affairs Dan Berger wrote. "However, the preamble of the proposed rule states that "this new section would require issuers to update variable APRs disclosed on mailed applications and solicitations every 60 days and variable APRs disclosed on applications and solicitations provided in electronic form every 30 days, and to update other terms when they change." NAFCU requests that the Board clarify that an update is only required if the applicable standard for accuracy…in the proposed ? 226.5a(c)(2) is not met."
CUNA's letter said the group was pleased with the elimination of timing and delivery requirement that were included in the 2001 interim final rules, particularly the requirement to send disclosures to a consumer's e-mail address, which will permit disclosure delivery via a credit unions home banking system.
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