The Federal Reserve Board on June 22, 2004, withdrew proposed revisions to Regulation B (Equal Credit Opportunity), Regulation E (Electronic Fund Transfers), Regulation M (Consumer Leasing), Regulation Z (Truth in Lending), and Regulation DD (Truth in Savings
The Board is also publishing final amendments to Regulation DD (Truth in Savings
) and Regulation M (Consumer Leasing).
Part 230, its Regulation DD, which implements the Truth in Savings
The Truth in Savings Act mandates that financial institutions disclose certain information about the terms of consumer deposit accounts in specific forms and at specific times.
To improve understanding of the process and costs of implementing regulatory changes, the Federal Reserve Board conducted the Survey of Compliance Costs for Truth in Savings in 1992-93, during the implementation period for the regulation.
Responses to the survey indicate that most banks provided extensive written disclosures to consumers before Truth in Savings but that most banks, if not all, had to change some policies and practices for consumer deposit accounts to comply with the law.
Third, the entire Board believes that the Truth in Savings
Act could be amended to make compliance less onerous but is divided on the merits of the approach taken in section 141 of the bill.
We cannot make the case, for example, that Call Reports, examinations, basic prudential standards, reserve requirements, antitrust, truth in lending, truth in savings, and the like should not apply only to some banks if they apply to any.
I might also add that regardless of their societal benefits, one cannot help but be impressed with the frequency and intensity of complaints by banks of all sizes about the heavy burden of paperwork costs for the Community Reinvestment Act--and those that will be involved in impending requirements of the Truth in Savings Act.
Thank you for the opportunity to offer the comments of the Board of Governors of the Federal Reserve System on H.R.6 and H.R.447 dealing with Truth in Savings.
Because of our experience with numerous consumer statutes for which we have rulewriting authority (for example, the Truth in Lending Act), we know firsthand that simple concepts such as "truth in savings" invariably result in complicated regulations.