CHASE
Chase Bank USA, N.A. | DE1-1023, 201 North Walnut Street, 10th floor, Wilmington, D E 1 9 8 0 1-2 9 2 0
Telephone: 302 282 3737 | Facsimile: 3 0 2 2 8 2 8 3 6 1
andrew.t.semmelman@chase.com
Andrew T. Semmelman
Senior Vice President
Associate General Counsel
July 17, 2008
Via Electronic Mail and U.S. Mail
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, DC 20551.
Re: Docket No. R-1286
Dear Ms. Johnson:
I. INTRODUCTION AND OVERVIEW
Chase Bank USA, N.A. (“Chase”), the consumer credit card bank subsidiary of JPMorgan Chase
& Co., appreciates the opportunity to comment on the additional proposed revisions to amend
Regulation Z, which implements the Truth in Lending Act (“TILA”), and the Regulation Z
Official Staff commentary (“Commentary”) to the Regulation (the “Proposal”) published in the
Federal Register on May 19, 2008 by the Board of Governors of the Federal Reserve (the
“Board”).
We appreciate the Board’s effort to ensure consumers have the information they need, in ways
they can understand, and applaud the commitment to enhancing consumers’ ability to use credit
cards to their benefit. At Chase, we share that objective, believing that the credit card
marketplace and economy are strengthened when consumers make informed decisions. In
general, we are supportive of the Proposal and pleased to offer these specific comments, which
are organized by topic, with citations to appropriate sections of the Proposal. We view it as an
opportunity to cast light on practices that non-issuers may not understand.
A. Consumer Testing
We support the approach used by the Board to seek input through consumer testing, and to use
that feedback in developing revisions that may help consumer understanding of the broad set of
disclosures required by the Regulation. This research is important in the overall scope of the
proposed changes. However, we respectfully submit that the findings from consumer testing
regardi