FTC Staff Comment Before the New York State Assembly Committee on Banks Concerning A.B. 6248-A to Continue Deregulation of Interest Rates and Service Charges and Require Disclosure of Certain Credit Terms

May 	29, 	1987
Federal Trade COnlml!;!;ion
Office (If the Regional Director
2G Federal 1'IR7,A. 22nd 1"1.
New Yurko New York 1027H
(2]2) 261-1200
~J\l1lj_
------------------ 6'7; 	1°
-®
Herman 	D. 	Farrell, 	Chairman
N.Y.S. 	Assembly 	Committee 	on 	Banks
State 	Capitol 	Building
Albany, 	N. 	Y. 	12248
Deae 	Chairman 	Farrell:
We 	are 	pleased 	to 	respond 	to 	your 	staff's 	invitation 	to
comment 	on 	Assemb~y Bill 	No. 	6248-A 	("A. 	6248-A"), 	a 	proposal 	to
continue 	deregulation 	of 	interest 	rates 	and 	service 	charges 	in
New 	York 	State 	for 	an 	additional 	four 	years 	and 	to 	require 	thaI
certain 	credit 	terms 	be 	disclosed 	in 	credit 	card 	applications.
Prior 	to 	1980, 	interest 	and 	finance 	charges 	applicable
to 	consumer 	debt 	were 	subject 	to 	a 	statutory 	ceiling. 2 	In 	1980
(as 	amended 	in 	1983), 	New 	York 	State 	suspended 	interest 	rate
regulation, 	buc 	only 	through 	June 	of 	this 	year. 	Unless 	A. 	6248-A
(or 	some 	comparable 	measure) 	is 	passed, 	therefore, 	New 	York
State's 	credit 	markets 	again 	will 	be 	gubject 	to 	interest 	rate
regulation 	as 	of 	July 	1.'
we 	believe 	that 	ccntinued 	deregulation 	of 	interest
charges 	would 	promote 	the 	availability 	of 	consumer 	credit 	and
would 	be 	beneficial 	to 	consumers. 	1n 	our 	view, 	consumer 	benafit
1 	This 	letter 	presents 	the 	views 	of 	the 	New 	York 	Regional 	Office
and 	the 	Sure.aus 	of 	Competition, 	Economics, 	and 	Consumer
Protection 	of 	the 	Federal 	Trade 	Commission, 	and 	not 	necessarily
those 	of 	the 	Commission 	itself. 	The 	Commission 	has, 	however,
voted 	to 	authorize 	th~ 	submission 	of 	these 	comments 	to 	you.
2 	See 	N.Y. 	Banking 	Law 	S 	l08(5)(b) 	(McKinney 	1971) 	and 	N.Y.
Personal 	Property 	Law 	5 	413(3) 	(McKinney 	1962).
New 	York 	State 	law 	distinguishes 	"interest," 	which 	is
applicable 	to 	loa~s of 	money, 	from 	"service 	charges," 	which 	are
applicable 	to 	installment 	purchases 	of 	goods 	and/or 	services.
Compare 	N.Y. 	Banking 	Law 	§ 	108(S)(b) 	(McKinney 	Supp. 	1987) 	with
N.Y. 	Personal 	property 	Law 	5401(12) 	(McKinney 	1962). 	We 	use 	the
term 	"interest" 	to 	refer 	to 	both 	interest 	and 	service 	charges.

Herman 	D. 	Farrell, 	Chairman 	- 	2 	-
can 	be 	maximized 	by 	permanent 	deregulation 	of 	interest 	rates.
Further, 	we 	believe 	tbat 	mandating 	disclosure 	of 	certain 	terms 	in
credit 	card 	applications 	(as 	distinguished 	from 	the 	present
requirement 	of 	disclosure 	prior 	to 	the 	first 	transaction) 	may
facilitate 	comparison 	shopping 	by 	credit 	card 	users. 	Such
disclosures 	would 	increase 	consumer 	welfare 	to 	the 	extent 	that
the 	costs 	of 	providing 	them 	are 	not 	greater 	than 	their 	benefits.
INTEREST 	CEILINGS 	INJURE 	CONSUMERS
The 	Federal 	Trade 	Commission 	("comm!ssion") 	enforces 	a
variety 	of 	laws 	pertaining 	to 	consumer 	credit 	and 	trade
practices 	in 	genecal. 4 	Our 	experience, 	as 	well 	as 	the 	economic
literature 	on 	consumer 	credit, 	indicates 	thgt 	interest 	rate
ceilings 	substantially 	hacln 	many 	consumers. 	Lenders, 	like 	all
others 	in 	the 	marketplace, 	must 	earn 	a 	competitive 	rate 	of 	return
or 	else 	leave 	the 	business. 	Therefore, 	when 	an 	imposed 	interest
rate 	ceiling 	is 	lower 	than 	the 	competitive 	market 	rate, 	lenders
must 	make 	adjustments 	by 	either 	increasing 	other 	charges,
3 	See, 	e.g., 	Truth-in-Lending 	Act, 	15 	U.S.C. 	S§ 	l601-l677e 	(198~
& Supp. 	III 	1985); 	Equal 	Credit 	Opportunity 	Act, 	15 	U.S.C.
S§ 	1691-1691f 	(1982 	& Supp. 	III 	1985); 	and 	Fair 	Credit 	Reporting
Act, 	15 	U.S.C. 	SS 	1681-1681t 	(1982 	& Supp. 	III 	1985).
4 	See, 	e.~., 	Section 	5 	of 	the 	Federal 	Trade 	Commission 	Act, 	15
U.S.C. 	§ 	4 	(1982); 	and 	Robinson-Patman 	Act, 	15 	U.S.C. 	SS 	13-
IJ(b), 	21a 	(1982 	& Supp. 	1111985).
5 	See, 	e.g., 	Canner 	& Fergus, 	The 	Economic 	Effects 	of 	proposed
Ceilings 	on 	Credit 	Card 	Interest 	Rates, 	Fed. 	Reserve 	Bull., 	Jan.
1987, 	at 	1; 	Nathan, 	Economic 	Anal 	sis 	of 	Usur 	Laws, 	10 	J. 	Bank
Res. 	200 	(1980); 	Ostas, 	E 	ects 	0 	Usury 	Cel 	lngs 	in 	the 	Mortgage
Market, 	31 	J. 	Fin. 	821 	(1976). 	See 	also 	Barth, 	The 	Effect 	of
Government 	He 	ulations 	on 	Personal 	Loan 	Markets: 	A Tobit
Estimation 	of 	a 	Microeconomlc 	Model, 	J. 	Fln. 	2).

Herman 	D. 	Farrell, 	Chairman 	- 	3 	-
reducing 	the 	vglurne 	of 	credit 	available 	to 	higher-risk 	borrowers,
or 	doing 	both.
The 	projected 	return 	on 	~ 	loan 	depends 	on 	the
likelihood 	of 	timely 	repayment, 	among 	other 	things. 	Accordingly,
lenders 	may 	wish 	to 	offer 	credit 	on 	different 	terms 	reflecting
borrowers' 	differing 	creditworthiness: 	a 	borrower 	with
substantial 	assets 	(particularly 	in 	relation 	to 	outstanding
indebtedness) 	and 	a 	solid 	history 	of 	timely 	repayment 	of 	loans
often 	may 	borrow 	at 	a 	lower 	rate 	of 	interest 	than 	a 	consumer 	with
few 	assets 	or 	a 	marginal 	credit 	history. 	Typically, 	however,
credit 	card 	issuers 	~nd 	some 	other 	lenders 	seek 	to 	make 	credit
- 	affo(dtible 	to 	an 	expanded 	pool 	of 	consumers 	-- 	including 	higher
risk 	borrowers. 	They 	do 	~o 	by 	offering 	credit 	on 	terms
reflecting 	the 	likelihood 	of 	timely 	repayment 	by 	pool 	members, 	on
average. 	However, 	if, 	as 	a 	result 	of 	interest 	rate 	regUlation,
such 	lenders 	are 	unable 	tu 	charge 	sufficient 	interest, 	they 	may
compensate 	by 	providing 	credit 	to 	the 	pool 	-- 	including 	even
lowest 	risk 	borrowers 	-- 	on 	les~ 	attractive 	terms. 	Hence, 	credit
card 	i~suers and 	other 	lenders 	may 	charge 	higher 	annual 	and
service 	fees, 	require 	larger 	minimum 	payments, 	increase
collateral 	requirements, 	~horten loan 	durations, 	reduce 	services,
and 	the 	like. 	Retail 	card 	issuers 	may 	also 	seek 	to 	offset
reductions 	in 	interest 	revenues 	by 	increasing 	merchandise 	prices
to 	all 	consumers, 	thus 	shifting 	the 	costs 	of 	credit 	transactions
to 	those 	whu 	pay 	cash, 	including 	thuse 	unable 	to 	qualify 	for
credit. 	Bank 	card 	issuers 	may 	attempt 	to 	increase 	the 	fees
charged 	to 	merchants 	for 	processing 	bank 	card 	sales.
6 	Villegas, 	T!)~ 	Impact 	of 	Usury 	Ceilings 	on 	Revolving 	Credit
(1986) 	(unpublished 	manuscript 	available 	from 	Arizona 	State
University 	Economics 	Department); 	Villegas, 	An 	Analysis 	of 	the:
Impact 	of 	Interest 	Rate 	Ceilings, 	37 	J. 	Fin. 	941 	(1982).
Alternatively, 	credit 	card 	issuers 	can 	remove 	their 	credit
card 	operations 	to 	states 	that 	have 	higher 	ur 	no 	interest 	rate
ceilings. 	Such 	banks 	will 	then 	be 	able 	to 	charge 	New 	York
consumers 	rates 	above 	the 	interest 	rate 	ceiling 	in 	New 	York.
Under 	the 	National 	Bank 	Act, 	12 	U.S.C. 	SS 	1-200 	(1982 	and 	Supp.
III 	1985), 	a 	natiuna1 	bank 	may 	charge 	its 	out-oE-state 	customers
an 	interest 	rate 	allowed 	by 	its 	home 	state, 	even 	when 	that 	rate
is 	greater 	than 	the 	interest 	rate 	permitted 	by 	the 	state 	of 	the
bank's 	nonresident 	customers. 	12 	U.S.C. 	S 	85 	(1982)1 	Marguette
Nat'l 	Bank 	of 	Minneapolis 	v. 	First 	of 	Omaha 	Servo 	Corp., 	439 	U.S.
299, 	313-18 	(1978).

Herman 	D. 	Farrell, 	Chairman 	- 	4 	-
8
If 	still 	unable 	to 	adjust 	interest 	charges 	to 	reflect
the 	average 	creditworthiness 	of 	pool 	members, 	lenders 	may
eliminate 	less 	creditworthy 	borrowers 	from 	the 	pool 	altogether,
in 	effect 	adjusting 	the 	pool, 	and 	h,nce 	the 	risk 	of 	default, 	to
reflect 	permitted 	interest 	charges. 	Excluded 	borrowers 	who
might 	otherwise 	have 	been 	able 	to 	obtain 	credit 	will 	include 	the
young, 	who 	often 	have 	little 	credit 	history, 	and 	people 	with 	less
9ub~tantial assets 	-- 	tile 	people 	mosL 	highly 	dependent 	on 	credit
for 	the 	purchase 	of 	clothing, 	furniture, 	and 	other 	basic 	items.
FREE 	MARKETS 	EFFICIENTLY 	ALLOCATE 	CREDIT
In 	the 	absence 	of 	governmental 	restriction, 	competition
among 	lenders 	will 	result 	in 	a 	variety 	of 	credit 	offerings
tending 	to 	fulfill 	the 	credit 	requirements 	of 	different
consumers. 	For 	example, 	a 	consumer 	who 	frequently 	defers 	payment
may 	s~lect 	a 	credit 	plan 	having 	relatively 	substantial 	initial
costs 	but 	lower 	interest 	charges. 	In 	contrast, 	a 	consumer 	who
enjoy~ 	the 	convenience 	of 	credit 	purchasing 	but 	seldom 	defers
payment 	may 	opt 	for 	a 	plan 	having 	lower 	initial 	costs 	but 	llighec
interest 	charges. 	Unrestricted 	credit 	markets, 	unlike 	regulated
credit 	markets, 	can 	efficiently 	serve 	such 	divergent 	consumer
interests.
A free 	market 	will 	provide 	these 	services 	without
excessive 	costs. 	Competition 	among 	lenders 	results 	in 	total
costs 	to 	consumers 	that 	generally 	reflect 	no 	more 	than 	creditors'
costs--igcludin g 	losses 	attributable 	to 	bad 	debt--and 	normal
p,o[it~. 	Firms 	that 	seek 	to 	earn 	suprftnormal 	profits 	will 	lose
business 	to 	other 	creditors. 	-
Studies 	provide 	evidence 	that 	over 	time 	creditors 	have
earned 	ne 	more 	than 	a 	competitive 	return 	on 	their 	invested
capital. 	The 	annual 	net 	earnings 	(before 	taxes) 	of 	bank 	~ard
plans 	averaged 	1.9 	percent 	of 	balances 	outstanding 	from 	1972
7 	Villegas' 	empirical 	findings 	support 	this 	conclu8ion. 	See 	The
Impact 	of 	Usury 	Ceilings 	on 	Revolving 	Credit, 	supra 	note 	6-.--
Canner 	& Fergus, 	sU2ra 	note 	5, 	at 	1-2.
9 	In 	other 	words, 	total 	costs 	to 	consumers 	have 	equalled
creditors' 	costs 	-- 	inclUding 	losses 	attributable 	to 	bad 	debt
and 	normal 	profits.

Herman 	D. 	Farrell, 	Chairman 	- 	5 	-
11
through 	1985. 	Over 	the 	same 	period, 	average 	net 	returns 	on 	other
major 	types 	of 	commercial 	bank 	lending 	were 	significantly 	higher:
2.3 	percent 	on 	real 	estate 	mortgages, 	2.4 	percent 	on 	consumer
in8tali~ent debt, 	and 	2.8 	percent 	on 	commercial 	and 	other
loans. 	Retail 	store 	credit 	card 	plans 	stand 	on 	a 	somewhat
different 	footing; 	studies 	show 	that 	those 	have, 	on 	average,
consistently 	operated1ft 	a 	loss, 	apart 	from 	consideration 	of
profit 	on 	goods 	sold.
To 	the 	extent 	that 	consumers 	bear 	higher 	charges 	for
credit 	card 	use 	than 	for 	some 	other 	forms 	of 	credit, 	the
difference 	appears 	to 	reflect 	the 	advantages 	of 	credit 	card
usc 	-- 	for 	example, 	preapproved 	and 	unsecured 	availability 	of
credit 	for 	purchases 	from 	a 	host 	of 	merchants 	-- 	rather 	than
greater 	returns 	to 	credit 	card 	issuers. 	All 	these 	features 	ace
costly 	for 	an 	issuing 	creditor 	to 	provide, 	which 	explains 	why 	the
relatively 	high 	interest 	rate 	does 	not 	necessarily 	imply 	the
existence 	of 	"exce~sive" profits 	to 	the 	creditor.
PERMANENT 	DEREGULATION 	IS 	APPROPRIATE
Notwithstanding 	this 	evidence 	of 	effective 	competition
among 	credit 	card 	issuers, 	the 	proponents 	of 	A. 	6248-A 	contend
that 	in 	recent 	y~ars credit 	card 	interest 	rates 	in 	New 	York 	State
have 	not 	reflected 	decreases 	in 	creditors' 	costs 	of 	funds. 	In
th~ir opinion, 	this 	is 	due, 	in 	part, 	to 	a 	lack 	of 	convenient
~omparatt2e information 	about 	the 	rates 	charged 	by 	different 	card
lSSU<HS.
We 	are 	unaware 	of 	any 	system~tic study 	conclUding 	that
credit 	card 	interest 	rates 	have 	been 	unresponsive 	to 	changes 	in
the 	cost 	of 	funds. 	Moreover, 	the 	cost 	of 	money 	constitutes 	a
10 Canner 	& Fergus, 	supra 	note 	5, 	at 	1-2 	(citing 	federal 	Reserve
Bank 	data).
Id. 	at 	2 	(citing 	two 	national 	surveys 	of 	retailers 	conducted
on 	behalf 	of 	the 	National 	Retail 	Merchants 	Association 	in 	1968
and 	1985 	and 	a 	1973 	study 	of 	retailers 	in 	New 	York).
12 	RegulQtion 	Z of 	the 	Truth-in-Lending 	Act 	requires 	that
pertinent 	disclu~ures be 	made 	prioe 	to 	the 	first 	credit
transaction 	using 	the 	card. 	12 	C.P'.R. 	Part 	226 	(1986). 	The
proponents 	of 	A. 	6248 	contend 	that 	such 	disclosures 	are 	provided
too 	ldte 	to 	facilitate 	comparison 	shopping 	by 	consumers.

l"I~U 	-- ..	•• e..",
Farrell, 	Chairman.
- 	6 	- 	\
much 	lower 	proportion 	of 	total 	cOr5s 	for 	credit 	card 	issuers 	th~n
for 	other 	major 	types 	of 	lenders. 	Thus, 	one 	would 	not 	expect'
interest 	rates 	applicable 	to 	credit 	cards 	to 	respond 	as
dramatically 	~s 	other 	in~erest rates 	to 	changes 	in 	the 	cost 	of
funds.
Herman 	D.
Moreover, 	competitive 	pressures 	appear 	now 	to 	have
forced 	credit 	card 	issuers 	to 	offer 	a 	variety 	of 	attractive
credit 	card 	plans. 	For 	example, 	American 	ExpreSS 	is 	offering 	its
new 	"Optima" 	card 	to 	its 	most 	valued 	American 	Express 	card
holders 	at 	a 	rate 	of 	13.5% 	per 	annum, 	and 	CitiBank 	is 	offering 	a
·Preferred 	HagterCard~ at 	16.8%. 	In 	addition, 	new 	sources 	of
revolving 	credit 	rapidly 	are 	developing, 	such 	as 	overdraft 	credit
lines 	on 	checking 	accounts 	and 	so-called 	"mall 	cards," 	which
provide 	credit 	at 	all 	retail 	outlets 	in 	a 	given 	shopping
center. 	These 	newer: 	credit 	offerings, 	in 	turn, 	increase 	the
pressure 	on 	conventional 	credit 	card 	issuers 	to 	compete 	f0 14	consumer 	allegiance 	on 	the 	basis 	of 	price 	and 	other 	terms.
Consumer 	credit 	markets 	currently 	seem 	to 	be 	operating 	.
competitively, 	and 	there 	appears 	to 	be 	no 	need 	for 	further
interest 	rate 	regulation.
DISCLOSURE 	REQUIREMENTS 	MAY 	ASSIST 	COMPARISON 	SHOPPING
If 	consumers 	actually 	value 	early 	~eceipt of 	credit
terms, 	we 	would 	expect 	credit 	card 	issuers 	to 	compete 	in 	the
provision 	of 	such 	information. 	In 	fact, 	some 	credit 	card 	issuers
now 	provide 	Truth-in-Lending 	Act 	disclosures 	not 	only 	in 	consumer
credit 	contracts 	but 	in 	applications 	aod 	solicitations 	as 	well.
Hence, 	the 	market 	alL"eady 	may 	be 	responding 	efficiently 	to
consumer s I 	in fo rma t ion 	ne~d:::l. 	None the 1 eS S, 	th~ 	in fo rma t ion
required 	to 	be 	disclosed 	by 	A. 	6248-A 	appears 	pertinent 	to 	well-
13 	Id.
14 	A survey 	of 	sixteen 	financial 	institutions 	(six 	within 	the
state 	of 	California) 	found 	that 	bank 	credit 	card 	plans 	had 	fixed
and 	variable 	interest 	rates 	between 	10.5% 	and 	15%. 	Moreover, 	the
survey 	disclosed 	that 	the 	lower-rate 	credit 	card 	plans 	offer
v~riety in 	other 	important 	terms, 	such 	as 	annual 	fees 	and 	grace
periods. 	Annual 	fe~s 	ranged 	from 	no 	charge 	to 	$22.50, 	and 	grace
periods 	of 	differing 	lengths 	were 	offered 	by 	t~n 	of 	the 	sixteen
institutions. 	Consumer 	Action's 	National 	Credit 	Card 	Survey
(1987).
....

Herman 	D. 	Farrell, 	Chairman 	- 	7 	-
informed 	decisionmaking 	by 	consumers, 	and 	may 	facilitate
increased 	comparison 	shopping. 	The 	disclosures 	can 	be 	expected
to 	increase 	consumer 	welfare 	as 	long 	as 	the 	costs 	of 	providing
them 	~re 	not 	greater 	than 	their 	benefits.
Sections 	2 	and 	3 	of 	A. 	6248-A 	would 	lsquire 	disclosure
of 	(1) 	the 	annual 	percentage 	rate 	of 	interest, 	(2) 	the 	amount
of 	any 	fee 	for 	participation 	in 	the 	card 	system, 	(3) 	the 	amount
of 	any 	late 	charges 	or 	uther 	fees, 	and 	(4) 	the 	length 	of 	any
period 	during 	which 	the 	consumer 	may 	pay 	the 	account 	balance
without 	incurring 	any 	interest 	charge. 	These 	disclosures 	would.
apply 	to 	any 	application 	form 	or 	preapproved 	written
solicitation, 	other 	than 	an 	application 	form 	or 	solicitation
included 	in 	a 	magazine, 	newspdper, 	or 	other 	publication. 	An
application 	included 	in 	a 	publication 	may 	use, 	in 	lieu 	of 	the
disclosures, 	a 	box 	that 	the 	consumer 	can 	check 	and 	return 	to 	the
creditor 	in 	order 	to 	obtain 	a 	disclosure 	circular. 	Required
disclosures 	must 	be 	in 	specified 	type 	faces 	and 	sizes 	and 	in 	a
prescribed 	format.
Two 	modifications, 	in 	particular, 	may 	permit 	the 	bill's
ubjectives 	to 	be 	accomplished 	at 	lower 	cost. 	First, 	a
requirement 	that 	the 	mandated 	disclosures 	be 	"clear 	and
'conspicuous," 	as 	is 	required 	under 	Regulation 	Z of 	the 	Truth-in-
Lending 	Act, 	could 	be 	substituted 	for 	the 	bill's 	rigid
specifications 	on 	format. 	This 	would 	permit 	multistate 	lenders
to 	comply 	readily 	with 	R~gulation Z and 	with 	otherwise
incon~i9tent disclosure 	laws 	that 	may 	be 	enacted 	in 	other
stat~s. 	The 	Assembly 	then 	may 	wish 	to:designat~ th~ 	disclosure
.. format 	contained 	in 	A. 	6248-A 	as 	a 	model 	format, 	use 	of 	which
would 	constitute 	compliance 	with 	the 	"clear 	and 	conspicuous"
standard.
Second, 	the 	disclosuc~ requirement 	could 	be 	limited 	tP
applications 	and 	solicitations 	that 	are 	distributed 	by 	mail.
Credit 	card 	issuers 	often 	distribute 	applications 	through
displays 	located 	on 	the 	premises 	of 	merchants. 	The 	issuer 	loses
effectiv~ ~ontrol of 	such 	ap~lications once 	it 	has 	forwarded 	them
Eor 	display. 	Thus, 	the 	credlt 	card 	issuer 	cannot, 	without
incurring 	substantial 	costs, 	continuously 	upd~te such
applications 	to 	reflect 	changes 	in 	credit 	terms. 	In 	lieu 	of 	its
present 	disclosur~ requirement, 	therefore, 	A. 	6248-A 	might
15 	If 	the 	interest 	rate 	charged 	is 	variable, 	the 	creditor 	must
so 	state 	and 	must 	disclose 	either 	the 	method 	by 	which 	the 	rat~ 	is
d~termined or 	the 	rate 	in 	effect 	on 	a 	date 	certain.

Herman 	o. 	Farrell, 	Chair-man 	- 	8 	-
provide 	that 	applications 	distributed 	other 	than 	by 	mail 	must
advise 	consumers 	that 	they 	can 	obtain 	a 	disclosure 	circular 	by
checking 	a 	box 	and 	returning 	the 	form 	to 	the 	credit 	card
issuer. 	In 	this 	manner 	the 	Assembly 	can 	ensure 	consumer 	access
to 	credit 	terms 	prioe 	to 	dpplication, 	without 	imposing 	undue
costs 	on 	credit 	card 	issuers.
CONCLUSION
Governmental 	regulation 	of 	interest 	rates 	may 	injure
COnSumers 	by 	inflating 	other 	costs 	of 	credit 	and 	reducing 	the
amount 	of 	credit 	available. 	In 	contrast, 	unregulated 	credit
markets 	usually 	allocate 	credit 	among 	consumers 	efficiently 	and
responsively. 	We, 	therefore, 	urge 	the 	Assembly 	to 	permanently
deregulate 	interest 	rates 	in 	New 	York 	State. 	Further, 	if 	the
Assembly 	is 	inclined 	to 	require 	early 	disclosure, 	it 	may 	wish 	to
consider 	the 	modifications 	discussed 	above. 	We 	believe 	that
enactment 	oC 	A. 	6248-A 	as 	so 	modified 	would 	6atisfy 	the 	intent 	of
the 	bill's 	framers 	without 	imposing 	excessive 	costs.
We 	hope 	that 	these 	comments 	assist 	the 	Assembly 	in 	its
deliberations. 	Please 	do 	not 	hesitate 	to 	contact 	us 	if 	you 	have
any 	questions 	or 	would 	like 	further 	information.
Very 	truly 	yours,
~~~~Regional-Director
TOTAL P.09