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America’s Community Bankers has told the Federal Reserve Board that it supports enhancing the disclosure of interest rates and other terms for credit and charge card solicitations and applications. Under a proposed revision in regulations, the disclosure box must use 18 point type to display the annual percentage rate and 12 point type for other contract terms.

"ACB fully supports the board’s efforts to ensure that consumer disclosures are clear and conspicuous and to enhance the ability of consumers to notice and understand the cost information and terms that generally must be provided in the form of a table," ACB said it its comment letter.

ACB suggested a flexible implementation time period to allow institutions to use up the remainder of existing forms. ACB noted that the changes "could have a significantly greater impact on smaller institutions if they are required to be instituted rapidly."

ACB cautioned that including too much additional information in the disclosures, such as the interest rate and transaction fees for balance transfers and the interest rate for cash advances, "may obscure the most important information."

ACB told the Fed it supports the use of electronic disclosures if the consumer elects to receive disclosures electronically.