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	<title>Comments on: Obama Calls for Credit Card Reform</title>
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		<title>By: Paul Lehto</title>
		<link>http://thedemocraticdaily.com/2009/05/09/obama-calls-for-credit-card-reform/comment-page-1/#comment-40010</link>
		<dc:creator>Paul Lehto</dc:creator>
		<pubDate>Sun, 10 May 2009 04:21:05 +0000</pubDate>
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		<description>A comment based in large part on my decade or so of past experience practicing consumer protection law:   

Transparency, while critically important, at bottom only provides data or information, and eliminates secrecy and surprise.  That&#039;s necessary, but not sufficient at all.

The entire sub-prime market is based on people who mostly can&#039;t qualify for reasonable terms and are forced into usurious terms at varying levels of unconscionability. For years, the Fair Credit REporting Act has required bold disclosures of the true cost of the credit, including all fees that are really disguised interest, so that the consumer is either informed on a basic level of the true cost of the credit or else (if there&#039;s nondisclosure) has a cause of action to sue.

Transparency (data) is like a clean windshield on a car, and clean windows on all sides, allowing us to know what&#039;s going on.  But without a steering wheel, gas pedal and brakes, or the POWER to do something about the information we receive via &quot;transparency&quot;, we might, much like someone caught on a railroad train track in front of an oncoming train without a working steering wheel or gas pedal, rationally prefer non-transparency to the horror of having information and not being able to act effectively upon it.

I support the transparency, but whether the bill is substantially improving things depends on the remedies and options consumers have in real life, not just in a better awareness of just how badly they&#039;re being taken to the cleaners by banks.</description>
		<content:encoded><![CDATA[<p>A comment based in large part on my decade or so of past experience practicing consumer protection law:   </p>
<p>Transparency, while critically important, at bottom only provides data or information, and eliminates secrecy and surprise.  That&#8217;s necessary, but not sufficient at all.</p>
<p>The entire sub-prime market is based on people who mostly can&#8217;t qualify for reasonable terms and are forced into usurious terms at varying levels of unconscionability. For years, the Fair Credit REporting Act has required bold disclosures of the true cost of the credit, including all fees that are really disguised interest, so that the consumer is either informed on a basic level of the true cost of the credit or else (if there&#8217;s nondisclosure) has a cause of action to sue.</p>
<p>Transparency (data) is like a clean windshield on a car, and clean windows on all sides, allowing us to know what&#8217;s going on.  But without a steering wheel, gas pedal and brakes, or the POWER to do something about the information we receive via &#8220;transparency&#8221;, we might, much like someone caught on a railroad train track in front of an oncoming train without a working steering wheel or gas pedal, rationally prefer non-transparency to the horror of having information and not being able to act effectively upon it.</p>
<p>I support the transparency, but whether the bill is substantially improving things depends on the remedies and options consumers have in real life, not just in a better awareness of just how badly they&#8217;re being taken to the cleaners by banks.</p>
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