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This is your last chance! We only have until
5 p.m. (EST) TODAY!!

Even if you have already submitted comment please please do so again! Due to some technical difficulty we are uncertain that all of the comments submitted thus far have been received. So please take the 5 minutes and submit or re-submit your thoughts!

We really need your help.We have a very limited amount of time to speak up to the Federal Reserve as they adopt administrative rules for the “Credit Card Accountability Responsibility and Disclosure Act of 2009” (CARD Act). In essence, this could have the ripple effect of pushing out local non-profit counseling agencies as consumers are directly sent to the three large call centers. Local agencies have the ability to refer customers to other local service providers so our families get the help they need. What we want the Federal Reserve to do is include a provision, just like they did on the HECM Ruling that mandates that one of the three phone numbers provided to consumers must be a local agency. This simple requirement can easily be implemented without additional expense to the creditors if they choose to utilize a counseling locator service such as the one provided by the National Foundation for Credit Counseling, Peregrine services, or other reputable providers. They need to know that consumers value and support local agencies.

Please click on this link

Or copy and paste this link into your browser: http://www.federalreserve.gov/generalinfo/foia/ElectronicCommentForm.cfm?doc_id=R-1370&doc_ver=1&name=Regulation%20Z%20-%20Truth%20in%20Lending&date=20090929a

And paste the below comments (or your own) into the comment box. Thank you for your consideration!

COMMENT TO INCLUDE
Right now we really need your help getting our voices heard at the Federal Reserve as they adopt administrative rules for the "The Credit Card Accountability Responsibility and Disclosure Act of 2009” (CARD Act).

I have recently been made aware of rule making by the Federal Reserve on the CARD Act that could have significant negative unintended consequences for the consumer. There is a line in the legislation that requires credit card companies to provide the consumer with a list of three credit counseling agencies each month on their statement. Though we are very happy to see this, there are ample opportunities for credit card companies to drive consumers to counseling agencies with which they have pre-determined agreements. The consumer would not receive an unbiased counseling session.

The proposed rule would require card issuers to provide through the toll-free telephone number disclosure contact information for at least three certified credit counseling services. CCCSMT firmly believes that within the provisions there needs to exist a mandate that one of the three numbers provided to consumers be that of a local nonprofit credit counseling agency. It is the opinion of CCCSMT that it is imperative that consumers are given the opportunity to elect a local credit counseling agency to provide financial services. By not placing this mandate within Regulation Z, the Board will severely limit consumer choice. Providing a local agency number will provide consumers accurate representation of the services available, thereby honoring the full disclosure spirit of the CARD Act. This is reference in the federal register/Vol.74, No. 202/Wednesday, October 21, 2009/proposed rule, page 54139. 127(b)(11)(B)(iii).

The importance of inclusion of a local credit counseling agency number goes beyond providing the consumer with choice. There are numerous advantages when a consumer is connected to a local credit counseling agency. The most important being the connection with the region in which the consumer lives. Predominantly, consumers seeking credit counseling services are experiencing financial difficulties. A local credit counseling agency can often connect them with additional resources within their communities and provide a more comprehensive approach to financial counseling. Most consumers find significant benefit to meeting in person with a financial counselor to work through their personal financial issues. This comprehensive approach to credit counseling significantly increases the consumer’s ability to become financial independent. If the Board does not ensure that the consumer is made aware of the credit counseling resources in their area, consumers will be placed at a significant disadvantage.

Furthermore, requiring a local counseling agency be included as one of the required choices brings this in line with a HUD ruling that requires housing counseling for seniors wishing to take a Home Equity Conversion Mortgage (HECM) be given contact information for a local HECM counselor. This was done to ensure lenders would not develop relationships with one counseling agency that would possibly steer them into options that would benefit the lender and not the consumer.

This simple requirement can easily be implemented without additional expense to the creditors if they choose to utilize a counseling locator service such as the one provided by the National Foundation for Credit Counseling, Peregrine services, or other reputable providers.

The comment period for this ends November 20 so time is of the essence. We need your help to ensure this critical aspect of the CARD Act is not overlooked! Please help us get this language included in the rules. I look forward to hearing from you soon.