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1 Final Recommendations on the Proposed Credit Practices Trade Regulation Rule [i] (1983)

handle is hein.usfed/fnrcpcp0001 and id is 1 raw text is: DATE: July 20, 1981 UNITED STATES GOVERNMENT memorandum Division of Credit Practices SUEJECT: Final Recommendations on the Proposed Credit Practices Trade Regulation Rule. Program K03. TO: Commission Attached please find the final recommendations of the rule- making staff in the proceeding on the proposed Credit Practices TRR. These recommendations are based on an analysis of the extensive record in this proceeding, together with the final comments received on the Staff and Presiding Officer Reports. Important revisions have been proposed for Section (a)(7) of the rule which addresses the problem of deficiency judgments. We also recommend deletion of Section (a)(6) which would require enumeration of collateral, and revisions of Section (b) of the rule which fences in cosigner liability. The requirement that cosigners be furnished with copies of all documents received by the principal debtor should be dropped. Finally, because of the complexity of this rule, we respect- fully recommend that the Commission request interested persons to submit statements in writing prior to the Oral Presentation. Such statements should be placed on the record and made avail- able to all interested persons. This will greatly facilitate preparation for the Oral Presentations and give the Commission and interested persons an opportunity to evaluate issues and prepare questions. Respectfu ly submitted, vit H. Williams /Program Advisor for Credit Practices Martin B. White, Christopher Keller, Norman E. Oliver, Attorneys, Division of Credit Practices Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan REPLY TO ATTN OF: A P PR D: ewis H. Goldf r Assistant Dire cr for credit Pra tices

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