Comments on: Even the Fed can’t get credit-card language right A slice of lime in the soda Sun, 26 Oct 2014 19:05:02 +0000 hourly 1 By: HBC Tue, 22 Jun 2010 18:52:36 +0000 It would come as more of a surprise if the Fed’s language were transparent, given the opacity of reasoning behind leaving the duplicitous Fed (of all people) in charge of civilian consumer protection. No conflict of interest could be more plain, yet remain undisclosed to all but those with magic decoder rings.

Even Fed members’ kids get the runaround. The question “What did you do in the war of plunder Wall Street waged against the US taxpayer, Fed Daddy?” provokes by way of response a litany of dumfounding flatulence, the gist of which being “As much as possible to help our side, the bad guys, of course!”

And there you have it, plain as daylight.

By: SteveVB Tue, 22 Jun 2010 17:54:12 +0000 Felix, you are definitely correct that the Fed’s sample language is not 100% accurate or clear. But, I think it is also important to note that Regulation Z also requires a notice when the Penalty APR is triggered that requires the institution to disclose (among other requirements):

“(3) The circumstances under which the delinquency or default rate or penalty rate, as applicable, will cease to apply to the consumer’s account, or that the delinquency or default rate or penalty rate will remain in effect for a potentially indefinite time period;” 12 CFR 226.9(g)

Here is a link to the Fed’s sample for that notice. pdfs/er22fe10.024.pdf

It does kind of feel like the Fed is between a rock and a hard place here. Some critics, such as Elizabeth Warren, claim disclosures are too long and complicated. Here, the Fed simplified the process and the language is still not clear to the average cardholder.”