Please accept the attached comments regarding the FRB and FTC's May 2008 proposal implementing the risk-based pricing notice requirements of the Fair and Accurate Credit Transactions Act of 2003 (FACTA), 15 U.S.C. § 1681m(h). These comments are filed on behalf of the low income clients of the National Consumer Law Center. If you have any questions or problems, please contact me. Thank you for your attention to this matter.