These comments are submitted by the National Consumer Law Center (on behalf of its low income clients), and the Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumers Union, Demos: A Network for Ideas & Action, National Association of Consumer Advocates, and U.S. Public Interest Research Group in response to the July 22, 2009 Interim Final Rule issued by the Federal Reserve Board. The Board’s Interim Final Rule implements two provisions of the Credit Card Accountability, Responsibility and Disclosures (CARD) Act of 2009.