What is 'Official Staff Commentary'

Official Staff Commentary is commentary published by the Federal Reserve that provides interpretations of regulations the Fed has issued.

BREAKING DOWN 'Official Staff Commentary'

Official Staff Commentary is published by the staff of the Federal Reserve, providing analysis and interpretation of regulations issued by the Fed. Official staff commentaries are used by the Fed’s Division of Consumer and Community Affairs to provide formal interpretations of regulations.

Using a question-and-answer format, Official Staff Commentaries are published periodically to provide explanations and insights on the often-complex Federal Reserve regulations. Official Staff Commentaries are published in the Federal Register and are accessible on the Internet via the Federal Reserve website, amongst other resources. Two commonly-cited Official Staff Commentaries respectively respond to Regulation E and Regulation Z.

Official Staff Commentary on Regulation E

In one commonly-cite instance, the Federal Reserve published an official staff commentary for Regulation E, which outlines procedures and guidelines for electronic funds transfers. The Fed issued Regulation E in order to implement the Electronic Funds Transfers Act of 1978.

In 2001, the Fed issued a revised Official Staff Commentary on Regulation E, to facilitate compliance by financial institutions in providing consumer electronic funds transfers. The updated commentary addressed electronic bill payments and check conversion transactions, authorization of recurring debits payments, telephone-initiated transfers, aggregation services and technical clarifications on a various other issues impacting electronic transactions.

Official Staff Commentary on Regulation Z

In 1998, the Fed published Official Staff Commentary responding to Regulation Z, which is part of the Truth in Lending Act of 1968. Regulation Z defines rules that protect consumers against fraud in the lending industry. Under Regulation Z, lenders such as credit card companies and mortgage companies are required to disclose terms to consumers in writing, and to refrain from unfair lending practices.

The 1998 Official Staff Commentary on Regulation Z provided guidance on how creditors determine whether credit is an open-end plan or a closed-end transaction, and how lenders offering open-end credit plans may increase rates triggered by late payments or exceeding credit limits. This commentary also addressed the treatment of annuity costs in reverse mortgage transactions, as well as the fees imposed on overdraft protection for checking account holders.

Who is Responsible for Official Staff Commentary

Official Staff Commentary is overseen by the Federal Reserve’s Board of Governors and the Fed’s Division of Consumer and Community Affairs.

The responsibilities of the Board of Governors include implementation of consumer protection laws and providing consumers with clear, comprehensive information regarding financial services transactions. The Board of Governors also promotes economic development and community lending, particularly in economically disadvantaged places.

The Division of Consumer and Community Affairs is commissioned with research and community outreach in order to inform and implement the actions and responsibilities of the Board of Governors.

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