These comments are submitted by the National Consumer Law Center (on behalf of its low-income clients), as well as the Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumers Union, Empire Justice Center, New York Legal Assistance Group, and the Sergent Shriver Center on Poverty Law.
The comments address the Federal Reserve Board’s November 2, 2010 Notice of Proposed Rulemaking, which proposes amendments to certain Regulation Z provisions implementing the Credit Card Accountability, Responsibility and Disclosures Act of 2009 (Credit CARD Act). 75 Fed Reg. 67,458 (November 2, 2010).