Comments of Greenville Heritage Federal Credit Union

Greenville Heritag e

FEDERAL CREDI T UNION

July 30 , 2008

Board of Governors of theFederal Reserve System Attn: Jennifer J. Johnson, Secretary 20th Stree t and Constitution Avenue , NW. Washington, DC 20551

Re: Regulatio n Z: Docket No. R-1286

Dear Ms. Johnson:

Greenville Heritag e Federal Credi t Union (GHFCU | sincerely appreciate s the opportunity t o comment o n (he Federal Reserve Board's (Board's ) proposed rul e on possible changes to the open-en d credit rules under Regulation Z, the Trut h in Lending Ac t (TILA). GHFCU is a federally insure d credit unio n with assets, of $29.9 million and a membershi p bas e of over 8,000 .

GHFCU request s tha t the Fed b e mindful of th e regulatory burden tha t i s imposed o n smal l institution s attempting t o

implement suc h drastic changes. I n the end, the costs associated with implementing these changes ha s the potential t o

have a negativ e impact on the membership by causin g increase d rates , fees and prohibition s o n special loa n promotions.

We furthe r request a sufficient amount time (at least 2 years) to implement these revisions once the final

regulatio n i s

approved.

GHFCU agree s that improvemen t i s needed to the disclosures bein g provided to consumers durin g the application proces s and throughou t the lif e o f the loan. W e express the followin g concern s i n regards to the various Regulation Z proposals :

> Payment Cut-off Times:

GHFCU supports the approach prohibiting from setting

a cut-off time before

5:00 p.m . o n the due date for

purposes o f determinin g whethe r a payment wil l be considered late. W e would lik e t o see this approac h expanded to

telephone and other electronic means. Payments received at any time during the business day should b e considered

received on that day and would view 5:00 p.m. to be the customary end of the busines s day.

If you have any questions about our comments, please contact me at {864) 467-4172.

Sincerely,

Angela F . Sprouse Chief Financial Office r

Home Office 75 Reedy View Drive Greenville, SC 29601 (864) 467-4160

County Square Office

Donaldson Center Office

301 University Ridge, Ste 2120400 Terminal Road

Greenville, SC 29601

Greenville, SC 29605

(864)467-7163

(864)299-7997

Toll Free (800) 943-6928 -

Simpsonville Office 350 Harrison Bridge Road Simpsonville, SC 29680 (864)228-6107

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