Comments on Proposed Changes to Truth In Lending Act

On behalf of the Retail Industry Leaders Association (RILA), I am writing with respect to the proposed changes to Regulation Z (Docket Number R-1384), which the Board of Governors of the Federal Reserve Board System (the Board) issued for public comment on March 3, 2010, and which are scheduled to take effect on August 22, 2010 (the Proposed Rule). As discussed fully below, RILA requests that the Board take into account concerns of the retail industry in finalizing the regulations governing the reasonableness and proportionality of penalty fees, particularly late-payment fees. RILA urges the Board to strike a balance between the need to provide clear and transparent late-payment fees and the importance of ensuring that they serve the purpose of promoting financial responsibility by the consumer.