United States:
Federal Register: FRB Proposes Amendment To Regulation M
09 January 2018
Cadwalader, Wickersham & Taft LLP
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The Board of Governors of the Federal Reserve System
("FRB") proposed amending
Regulation M, which was issued to implement the Consumer
Leasing Act ("CLA"). The CLA requires "meaningful
disclosure of the terms of personal property leases for personal,
family, or household use."
The CLA transferred rulemaking authority from the FRB to the
CFPB. However, the FRB maintains authority to issue rules for
"motor vehicle dealers that are predominantly engaged in the
sale and servicing of motor vehicles, the leasing and servicing of
motor vehicles, or both, and are otherwise not subject to the
[CFPB]'s regulatory authority." The FRB proposal revises
both Regulation M and accompanying Official Staff Commentary in
order to reflect the change in the scope of Regulation M.
Interested parties must submit comments to the FRB by March 5,
2018.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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