Proposed Board Interpretations of Regulation Z, Circular No. 77-5

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F e d e r a l r e s e r v e B a n k o f D a l l a s D A L LA S, T E X A S 7 5 2 2 2 C irc u la r No, 77-5 January 5, 1977 PROPOSED BOARD INTERPRETATIONS OF REGULATION Z Lease Disclosure Statements TO ALL BANKS, OTHER CREDITORS, AND OTHERS CONCERNED IN THE ELEVENTH FEDERAL RESERVE D ISTRICT:

The Board of Governors of the Federal Reserve System has published for public comment proposed sample forms and instructions that could be used by lessors to comply with the Board's regulations implementing the Consumer Leasing Act of 1976.

The three sample forms and the accompanying instructions for th eir use w ere proposed as Board interpretations of its Regulation Z (which implements the T ru th -in -L e n d in g Act and the Consumer Leasing Act) . When p ro p erly used, the forms would constitute adequate disclosure of lease terms as required by Regulation Z .

The Board amended Regulation Z to c a rry out the provisions of the leasing act on October 13, 1976. T h e act and its implementing regulation become effective March 23, 1977.

Th e forms proposed concern three types of leasing: open-end and closed-end, vehicle leasing, and fu rn itu re leasing. They constitute disclosure statements and not lease contracts.

Th e Board asked that comment be directed especially to the adequacy and in te llig ib ility of the instructions for using the disclosure forms; style, fo r­ mat, design, and the use of sim plified language in the form s, w hether additional or less information should be included in the forms; w hether there are problems inherent in the types of leasing involved not addressed to the proposed in te rp re ­ tations and whether the disclosure language of Item 14 of the open-end vehicle leasing statement (Interpretation Sec. 226.1501) is an adequate and readily understandable statement of the limitations of the lessee's liab ility at the end of the lease term .

Any questions about the proposed interpretations should be directed to our Regulations Department at (214) 651-6169. A copy of the proposed in ter­ pretations, as submitted for publication in the FEDERAL REGISTER, w ill be furnished upon request to the Secretary's Office of this Bank (214) 651-6267. This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library ([email protected])

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- The deadline for receipt of w ritten comments is January 21, 1977. Comments should be addressed to the S ecretary, Board of Governors of the Federal Reserve System, Washington, D .C . 20551. Comments should include a reference to Docket No. R-0070.

Sincerely y o u rs, Robert H . Boykin First Vice President