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1 Timothy J. Muris, Credit Practices TRR: Memorandum to the Commission 1 (1983)

handle is hein.usfed/cdptrr0001 and id is 1 raw text is: FEDERAL TRADE COMMISSION WASHINGTON. D. C. 20580 Program Code K03 BUREAU OF CONSUMER PROTECrION OF April 4, 1983 COVINGTON & BURLIN6 MEMORANDUM TO: Commission FROM: Timothy J. Director SUBJECT: Credit Practices TRR I am forwarding the staff's final recommendations for the Credit Practices Trade Regulation Rule. The proposed rule would regulate the contracts that creditors and consumers now agree to sign, prohibiting some terms and requiring others. The Commission should terminate this proceeding. In proposing this rule, the Commission stated that it would only adopt the rule if the record revealed that consumers cannot avoid the contract clauses at issue and if the benefits of each rule provision exceed the costs. The record indicates that the rule has not met these tests. According to the evidence, consumers have options. The evidence also indicates that this rule would probably cost consumers more than it is worth. Moreover, the costs would primarily affect the intended beneficiaries of the rule, those who are most in need of credit. If this rule is promulgated, lenders will be more reluctant to lend to higher risk borrowers. Low income consumers and those without established credit histories will find credit more difficult to obtain. Everyone will find credit more costly. This memorandum discusses the rule in detail. It is organized as follows:

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