Comments of the Ohio Treasurer of State
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ATTN: FEDERAL RESERVE RE: OHIO COMMUNITY RESOLUTIONS AND CITIZEN COMMENTS DOCKET # R -1314 (REGULATION AA) DATE: JUNE 30, 2008 CC: OFFICE OF THRIFT SUPERVISION NATIONAL CREDIT UNION ADMINISTRATION July 30, 2008 The Honorable Ben S. Bernanke Chairman, Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, D.C. 20551 RE: Docket #R-1314 (Regulation AA) Dear Chairman Bernanke: In the Ohio Treasury, we keenly focus on helping citizens better manage their personal finances. We host seminars and conferences, and created an interactive web site at www.yourmoneynowonline.org. While education is important, we also recognize the essential need for responsible regulation of improper and abusive credit practices in helping people navigate an increasingly complex financial world. We therefore strongly support the proposed changes to Regulation AA, which will place consumers and credit card companies on a more level playing field. Practices such as double-cycle billing, universal default, unreasonable payment dating, and raising interest rates on pre-existing balances, have unfairly cost consumers billions of dollars. We know this firsthand from surveying participants in our financial literacy programs and hearing countless stories of financial lives undermined by such abuses. For these reasons, the Ohio Treasury took seriously the request for public comment from the Federal Reserve Board, Office of Thrift Supervision, and National Credit Union Administration, on the proposed changes to Regulation AA. The reaction from citizens has been overwhelming. We are proud to transmit comments received from 4,623 Ohioans who have suffered from unfair and deceptive credit practices, all of which are included for your consideration. And we are pleased to have received statements of support from 55 local governments, representing 4,774,379 Ohioans. These resolutions are attached for your review. Together, these voices demonstrate that Ohioans demand and deserve reform of the credit card industry. We urge you to heed their collective plea by approving Regulation AA’s proposed changes. These regulations are long overdue and represent a strong step in the right direction. Thank you for your important work on these issues and for giving these comments the careful attention that they merit. Sincerely, Richard Cordray Ohio Treasurer cc: Office of Thrift Supervision National Credit Union Administration Ashtabula City Council Resolutions Athens County Commissioners Bedford Heights City Council Broadview Heights City Council Brook Park City Council Brooklyn City Council Brown County Commissioners Bucyrus City Council Canton City Council Carroll County Commissioners Champaign County Commissioners Cleveland City Council Cleveland Heights City Council Columbus City Council Conneaut City Council Crawford County Commissioners Cuyahoga County Commissioners Euclid City Council Fairview Park City Council Galion City Council Gallia County Commissioners Garfield Heights City Council Girard City Council Greene County Commissioners Hardin County Commissioners Harrison County Commissioners Hilliard City Council Huron County Commissioners Lake County Commissioners Lancaster City Council Lorain County Commissioners Mahoning County Commissioners Marysville City Council Massillon City Council Middleburg Heights City Council Montgomery County Commissioners Niles City Council North Olmsted City Council North Royalton City Council Ottawa County Commissioners Parma Heights City Council Richland County Commissioners Riverside City Council Ross County Commissioners Scioto County Commissioners Solon City Council Stark County Commissioners Streetsboro City Council Strongsville City Council Van Wert City Council Wickliffe City Council Willowick City Council Wooster City Council Worthington City Council Youngstown City Council 1 2 3 4 5 6 7 AGENDA BROOKLYN CITY COUNCIL Regular Meeting ~ June 23, 2008 Pledge of Allegiance Roll Call Approval of minutes of May 27, 2008 Public Session Reports from Committees, Commissions and Boards Reports of Council Directors' Reports Liquor Permit (transfer 3580 Ridge Rd) Resolution #200815: In support of the proposed Brooklyn School District's 6.6 mill levy on August 5, 2008 Resolution #200816: Authorizing the Mayor of the City of Brooklyn to apply as a coapplicant with the City of South Euclid (lead applicant) and other First Ring Suburbs Development Council communities to the State of Ohio Department of Development's 'Local Services and Regional Collaboration Grant Program' Resolution #200817: To urge the National Credit Union Administration, the Federal Reserve Board, and the Office of Thrift Supervision to adopt the reforms proposed for the Federal Trade Commission Act, Truth in Savings Act, and Truth in Lending Act to protect consumers from unfair and abusive practices by the credit card industry Resolution #200818: Adopting the Tax Budget for the Fiscal Year 2009 Resolution #200819: Supporting the I480/Tiedeman Road Interchange Modification Project and stating that the final design will be the Diverging Diamond Interchange Ordinance #200836 Amended (3rd Reading/Adoption): Enacting Chapter 151 of the Codified Ordinances of the City of Brooklyn, Ohio, entitled 'Brooklyn Community Improvement Corporation' and approving the formation of the Brooklyn Community Improvement Corporation Ordinance #200846: Authorizing the Mayor to enter into a contract with TraffTech, Inc. for the 2008 Street Striping Program Ordinance #200847: To amend Section 1 of Ordinance 20088, adopted January 28, 2008, as amended by Ordinance 200843, adopted June 9, 2008, and titled 'An Ordinance establishing a temporary moratorium on the acceptance and processing of applications for permits for electronic message signs and the issuance of such permits; and declaring an emergency' Ordinance #200848: Authorizing the Mayor of the City of Brooklyn, Ohio to enter into an agreement with Great Lakes Billing Associates, Inc. for third party EMS and ambulance billing, consultation, and related services Ordinance #200849: To amend Section 143.02 of the Codified Ordinances of the City of Brooklyn, Ohio entitled 'EMS Service Charges' Other matters that may come before the Council Adjournment 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 R E S O L U T I O N Urging the National Credit Union Administration, Federal Reserve Board and Office of Thrift Supervision to adopt proposed reforms to the Federal Trade Commission Act, Truth in Savings Act and Truth in Lending Act to protect consumers from unfair and abusive practices by the credit card industry. WHEREAS, many responsible consumers are being harmed by a growing number of fees, penalties and interest charges attached to bill payments and credit card debts. WHEREAS, the home foreclosure crisis serves as a daily reminder of the need for responsible federal regulation to protect citizens from unfair or predatory business practices. WHEREAS, the proposal from the National Credit Union Administration, the Federal Reserve Board and the Office of Thrift Supervision will help consumers in our community avoid excess fees and unfair charges that put their personal financial stability in jeopardy. WHEREAS, the proposed regulations will put an end to business practices that only serve to increase the amount of interest and fees that are owed and trap more consumers in a cycle of debt. WHEREAS, the proposed regulations will help to provide responsible consumers with greater piece of mind that the terms they agreed to when they opened their credit card accounts will not be changed unexpectedly or without their knowledge. WHEREAS, through the adoption of these principles, the National Credit Union Administration, the Federal Reserve Board and the Office of Thrift Supervision will help to protect our community’s quality of life by preventing financial hardship and lessening the demands on our local social-service providers for help. AND WHEREAS, this resolution constitutes an emergency measure for the immediate preservation of public peace, property, health and/or safety. NOW, THEREFORE, BE IT RESOLVED that the Board of County Commissioners of Cuyahoga County, Ohio, urges the National Credit Union Administration, Federal Reserve Board and the Office of Thrift Supervision to adopt proposed reforms to the Federal Trade Commission Act, Truth in Savings Act and Truth in Lending Act to protect consumers from unfair and abusive practices by the credit card industry. BE IT FURTHER RESOLVED that the Clerk of the Board be, and she is, hereby instructed to transmit a copy of this resolution to Paul Oyaski, Director, Department of Development; the National Credit Union Administration, the Federal Reserve Board, the Office of Thrift Supervision and the members of the Ohio’s Congressional delegation via Ohio Treasurer Richard Cordray’s Office. 29 On Motion of Commissioner Hagan, seconded by Commissioner Dimora, the foregoing resolution was duly adopted. Ayes: Hagan, Dimora, Jones. Nays: None. Resolution Adopted. Andria Richardson, Clerk of the Board pro tem Journal 299 June 26, 2008 082901 fg 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 Citizen Comments 96 Name: Leann Thacker County: Warren State: Ohio Comments: If someone took money from me on the street they would be in jail. Why should a company be allowed to do so each month legally? Name: Eve Baldwin County: Wood State: Ohio Comments: I firmly agree with the changes. It is about time! Name: Dan Moon City: columbus County: Franklin State: Ohio Comments: When we use a credit card for a purchase, we do so with our budget in mind. Then the credit card companies change the terms of interest, payments. No wonder so many peple are bankrupt and losing their homes. No other type of consumer finance can change terms like that unilaterally- your car payment can not double for no reason. Name: Joyce Wiechelman City: Chilicothe County: Ross State: Ohio Comments: Credit card companies are permitted too high an interest limit.