,,ii #aacth ,,congress #ast ,session ,s4 #abjh ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,june #bj1 #bjac ,mr4 ,tester 7for himself and ,mr4 ,moran7 introduced the following bill2 which was read twice and referred to the ,committee on ,banking1 ,housing1 and ,urban ,affairs ,a ,,bill ,to require meaningful disclosures of the terms of rental-purchase agreements1 including disclosures of all costs to consumers under such agreements1 to provide certain substantive rights to consumers under such agreements1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,consumer ,rental ,purchase ,agreement ,act4 #b4 ,findings and declaration of purpose 7a7 ,findings ,congress finds that-- 7#a7 the rental-purchase industry provides a service that meets and satisfies the demands of many consumers2 7#b7 each year1 approximately #b1cjj1jjj ,united ,states households enter into rental-purchase transactions1 and over a #e-year period1 approximately #d1ijj1jjj ,united ,states households will do so2 7#c7 competition among the various firms engaged in the extension of rental-purchase transactions would be strengthened by informed use of rental-purchase transactions2 and 7#d7 the informed use of rental-purchase transactions results from an awareness of the cost thereof by consumers4 7b7 ,purpose ,the purpose of this ,act is to ensure the availability of rental-purchase transactions and to ensure simple1 meaningful1 and consistent disclosure of rental-purchase terms so that consumers will be able to more readily compare the available rental-purchase terms and avoid uninformed use of rental-purchase transactions1 and to protect consumers against unfair rental-purchase practices4 #c4 ,definitions ,for purposes of this ,act1 the following definitions shall apply3 7#a7 ,advertisement ,the term advertisement means-- 7,a7 a commercial message in any medium that promotes1 directly or indirectly1 a rental-purchase agreement2 and 7,b7 does not include any price tag1 window sign1 or other in-store merchandising aid4 7#b7 ,agricultural purpose ,the term agricultural purpose includes-- 7,a7 the production1 harvest1 exhibition1 marketing1 transformation1 processing1 or manufacture of agricultural products by a natural person who cultivates plants or propagates or nurtures agricultural products2 and 7,b7 the acquisition of farmlands1 real property with a farm residence1 or personal property and services used primarily in farming4 7#c7 ,cash price ,the term cash price means the price at which a merchant1 in the ordinary course of business1 offers to sell for cash the property that is the subject of the rental-purchase transaction4 7#d7 ,commission ,the term ,commission means the ,federal ,trade ,commission4 7#e7 ,consumer ,the term consumer means a natural person who is offered or enters into a rental-purchase agreement4 7#f7 ,date of consummation ,the term date of consummation means the date on which a consumer becomes contractually obligated under a rental-purchase agreement4 7#g7 ,initial payment ,the term initial payment means the amount to be paid before or at the consummation of the agreement1 or the delivery of the property1 if delivery occurs after consummation1 including-- 7,a7 the rental payment2 7,b7 service1 processing1 or administrative charges2 7,c7 any delivery fee2 7,d7 any refundable security deposit2 7,e7 taxes2 7,f7 mandatory fees or charges2 and 7,g7 any optional fees or charges agreed to by the consumer4 7#h7 ,merchant ,the term merchant means a person who provides the use of property through a rental-purchase agreement in the ordinary course of business and to whom an initial payment by the consumer under the agreement is payable4 7#i7 ,payment schedule ,the term payment schedule means the amount and timing of the periodic payments and the total number of all periodic payments that the consumer will make if the consumer acquires ownership of the property by making all periodic payments4 7#aj7 ,periodic payment ,the term periodic payment means the total payment that a consumer will make for a specific rental period after the initial payment1 including the rental payment1 taxes1 mandatory fees or charges1 and any optional fees or charges agreed to by the consumer4 7#aa7 ,property ,the term property means property that is not real property under the laws of the ,state in which the property is located when it is made available under a rental-purchase agreement4 7#ab7 ,rental payment ,the term rental payment means rent required to be paid by a consumer for the possession and use of property for a specific rental period1 but does not include taxes or any fees or charges4 7#ac7 ,rental period ,the term rental period means a week1 month1 or other specific period of time1 during which the consumer has a right to possess and use property that is the subject of a rental-purchase agreement after paying the rental payment and any applicable taxes for such period4 7#ad7 ,rental-purchase agreement 7,a7 ,in general ,the term rental-purchase agreement means a contract in the form of a bailment or lease for the use of property by a consumer for an initial period of #d months or less1 that is renewable with each payment by the consumer1 and that permits but does not obligate the consumer to become the owner of the property4 7,b7 ,exclusions ,the term rental-purchase agreement shall not be construed to be1 nor be governed by laws regulating1 any of the following3 7i7 ,a credit sale 7as defined in section #ajc7;g7 of the ,truth in ,lending ,act 7#ae ,u4,s4,c4 #afjb7;g7774 7ii7 ,a consumer lease 7as defined in section #aha7a7 of the ,truth in ,lending ,act 7#ae ,u4,s4,c4 #affg7a7774 7iii7 ,an extension of credit or a transaction giving rise to a debt incurred in connection with the purchase of a thing of value4 7#ae7 ,rental-purchase cost 7,a7 ,in general ,for purposes of sections #ajaj and #ajaa1 the term rental-purchase cost means the sum of all rental payments and mandatory fees or charges imposed by the merchant as a condition of entering into a rental-purchase agreement or acquiring ownership of property under a rental-purchase agreement1 such as-- 7i7 a service1 processing1 or administrative charge2 7ii7 a fee for an investigation or credit report2 or 7iii7 a charge for delivery required by the merchant4 7,b7 ,excluded items ,the following fees or charges shall not be taken into account in determining the rental-purchase cost with respect to a rental-purchase transaction3 7i7 ,fees and charges prescribed by law1 which actually are or will be paid to public officials or government entities1 such as sales tax4 7ii7 ,fees and charges for optional products and services offered in connection with a rental-purchase agreement4 7#af7 ,state ,the term ,state means any ,state of the ,united ,states1 the ,district of ,columbia1 any territory of the ,united ,states1 ,puerto ,rico1 ,guam1 ,american ,samoa1 the ,trust ,territory of the ,pacific ,islands1 the ,virgin ,islands1 and the ,northern ,mariana ,islands4 7#ag7 ,total cost ,the term total cost means the sum of the initial payment and all periodic payments in the payment schedule to be paid by the consumer to acquire ownership of the property that is the subject of a rental-purchase agreement4 #d4 ,exempted transactions ,this ,act shall not apply to rental-purchase agreements primarily for business1 commercial1 or agricultural purposes1 or those made with ,government agencies or instrumentalities4 #e4 ,general disclosure requirements 7a7 ,recipient of disclosure ,a merchant shall disclose to any person who will be a signatory to a rental-purchase agreement the information required by sections #f and #g4 7b7 ,timing of disclosure ,the disclosures required under sections #f and #g shall be made-- 7#a7 before the consummation of the rental-purchase agreement2 and 7#b7 clearly and conspicuously1 in writing1 as part of the rental-purchase agreement to be signed by the consumer4 7c7 ,clearly and conspicuously ,as used in this section1 the term clearly and conspicuously means that information required to be disclosed to the consumer shall be worded plainly and simply1 and appear in a type size1 prominence1 and location as to be readily noticeable1 readable1 and comprehensible to an ordinary consumer4 #f4 ,rental-purchase disclosures 7a7 ,in general ,for each rental-purchase agreement1 the merchant shall clearly and conspicuously disclose to the consumer1 to the extent applicable-- 7#a7 the date of the consummation of the rental-purchase transaction and the identities of the merchant and the consumer2 7#b7 a brief description of the rental property1 which shall be sufficient to identify the property to the consumer1 including an identification or serial number1 if applicable1 and a statement indicating whether the property is new or used at the time of the agreement2 7#c7 a description of any fee1 charge1 or penalty1 in addition to the periodic payment1 that the consumer may be required to pay under the agreement1 which shall be separately identified by type and amount2 7#d7 a statement that-- 7,a7 the transaction is a rental-purchase agreement2 and 7,b7 the consumer will not obtain ownership of the property until the consumer has paid the total dollar amount necessary to acquire ownership2 7#e7 the amount of any initial payment2 7#f7 the amount of the cash price of the property that is the subject of the rental-purchase agreement1 and1 if the agreement involves the rental of #b or more items as a set 7as may be defined by the ,commission1 by regulation7 a statement of the aggregate cash price of all items shall satisfy this requirement2 7#g7 the payment schedule2 7#h7 the total cost1 using that term1 and a brief description1 such as ,this is the amount you will pay the merchant if you make all periodic payments to acquire ownership of the property42 7#i7 a statement of the right of the consumer to terminate the agreement without paying any fee or charge not previously due under the agreement1 by voluntarily surrendering or returning the property in good repair upon expiration of any rental period2 7#aj7 a description of the reinstatement periods of terminated rental-purchase agreements2 and 7#aa7 substantially the following statement3 ,,other ,,important ,,terms3 ,see your rental-purchase agreement for additional important information on early termination procedures1 purchase option rights1 responsibilities for loss1 damage1 or destruction of the property1 warranties1 maintenance responsibilities1 and other charges or penalties you may incur44 7b7 ,form of disclosure ,the disclosures required by paragraphs 7#d7 through 7#ab7 of subsection 7a7-- 7#a7 shall be segregated from other information at the beginning of the rental-purchase agreement2 7#b7 shall contain only directly related information2 and 7#c7 shall be identified in boldface1 upper-case letters as follows3 ,,important ,,rental-,,purchase ,,disclosures4 7c7 ,disclosure requirements relating to insurance premiums and liability waivers 7#a7 ,in general ,the merchant shall clearly and conspicuously disclose in writing to the consumer before the consummation of a rental-purchase agreement that the purchase of leased property insurance or liability waiver coverage is not required as a condition for entering into the rental-purchase agreement4 7#b7 ,affirmative written request after cost disclosure ,a merchant may provide insurance or liability waiver coverage1 directly or indirectly1 in connection with a rental-purchase transaction only if-- 7,a7 the merchant clearly and conspicuously discloses to the consumer the cost of such coverage before the consummation of the rental-purchase agreement2 and 7,b7 the consumer signs an affirmative written request for such coverage after receiving the disclosures required under paragraph 7#a7 and subparagraph 7,a7 of this paragraph4 7d7 ,accuracy of disclosure 7#a7 ,in general ,the disclosures required to be made under subsection 7a7 shall be accurate as of the date on which the disclosures are made1 based on the information available to the merchant4 7#b7 ,information subsequently rendered inaccurate ,if information required to be disclosed under subsection 7a7 is rendered inaccurate as a result of any agreement between the merchant and the consumer subsequent to the delivery of the required disclosures1 the resulting inaccuracy shall not constitute a violation of this ,act4 #g4 ,other agreement provisions 7a7 ,in general ,each rental-purchase agreement shall-- 7#a7 provide a statement specifying whether the merchant or the consumer is responsible for loss1 theft1 damage1 or destruction of the property2 7#b7 provide a statement specifying whether the merchant or the consumer is responsible for maintaining or servicing the property1 together with a brief description of the responsibility2 7#c7 contain a provision for reinstatement of the agreement1 which1 at a minimum-- 7,a7 permits a consumer who fails to make a timely rental payment to reinstate the agreement1 without losing any rights or options which exist under the agreement1 by the payment of all past due rental payments and any other charges then due under the agreement and a payment for the next rental period-- 7i7 within #g business days after failing to make a timely rental payment1 if the consumer pays monthly2 or 7ii7 within #c business days after failing to make a timely rental payment1 if the consumer pays more frequently than monthly2 7,b7 if the consumer returns or voluntarily surrenders the property covered by the agreement1 other than through judicial process1 during the applicable reinstatement period set forth in subparagraph 7,a71 permits the consumer to reinstate the agreement during a period of at least #fj days after the date of the return or surrender of the property by the payment of all amounts previously due under the agreement1 any applicable fees1 and a payment for the next rental period2 7,c7 if the consumer has paid #ej percent or more of the total cost necessary to acquire ownership and returns or voluntarily surrenders the property1 other than through judicial process1 during the applicable reinstatement period set forth in subparagraph 7,a71 permits the consumer to reinstate the agreement during a period of at least #abj days after the date of the return of the property by the payment of all amounts previously due under the agreement1 any applicable fees1 and a payment for the next rental period2 7,d7 if the consumer is a member of the ,armed ,forces and returns or voluntarily surrenders property as set forth in subparagraph 7,a7 due to a permanent change of station or other relocation of the member1 provides that the applicable reinstatement period set forth in subparagraph 7,b7 or 7,c7 be tolled or otherwise suspended until such time as the consumer returns to the area where the property is located2 and 7,e7 permits the consumer1 upon reinstatement of the agreement to receive the same property1 if available1 that was the subject of the rental-purchase agreement1 or if the same property is not available1 a substitute item of comparable quality and condition may be provided to the consumer1 except that1 the ,commission may1 by regulation or order1 exempt any independent small business 7as defined by the ,commission1 by regulation7 from the requirement of providing the same or comparable product during the extended reinstatement period provided in subparagraph 7,c71 if the ,commission determines1 taking into account such standards as the ,commission determines to be appropriate1 that the reinstatement right provided in such subparagraph would provide excessive hardship for such independent small business2 7#d7 provide a statement specifying the terms under which the consumer shall acquire ownership of the property that is the subject of the rental-purchase agreement1 either by payment of the total cost to acquire ownership1 as provided in section #h1 or by exercise of any early purchase option provided in the rental-purchase agreement2 7#e7 provide a statement disclosing that if any part of an express warranty of the manufacturer covers the property at the time the consumer acquires ownership of the property1 the warranty will be transferred to the consumer1 if allowed by the terms of the warranty2 and 7#f7 provide1 to the extent applicable1 a description of-- 7,a7 any grace period for making any periodic payment2 7,b7 the amount of any security deposit1 to be paid by the consumer upon initiation of the rental-purchase agreement2 and 7,c7 the terms for refund of such security deposit to the consumer upon return1 surrender1 or purchase of the property4 7b7 ,repossession during reinstatement period ,subsection 7a77#c7 may not be construed so as to prevent a merchant from attempting to repossess property during the reinstatement period pursuant to subsection 7a77#c77;,a71 but such a repossession does not affect the consumer's right to reinstate in accordance with this ,act4 #h4 ,right to acquire ownership 7a7 ,in general ,the consumer shall acquire ownership of the property that is the subject of a rental-purchase agreement1 and the rental-purchase agreement shall terminate1 upon compliance by the consumer with the requirements of subsection 7b7 or any early payment option provided in the rental-purchase agreement1 and upon payment of any past due payments and fees1 as permitted in regulation by the ,commission4 7b7 ,payment of total cost ,the consumer shall acquire ownership of the rental property upon payment of the total cost of the subject rental-purchase agreement1 as disclosed to the consumer in the rental-purchase agreement pursuant to section #f7;a74 7c7 ,additional fees prohibited 7#a7 ,in general ,a merchant shall not require the consumer to pay1 as a condition for acquiring ownership of the property that is the subject of a rental-purchase agreement1 any fee or charge in addition to1 or in excess of1 the regular periodic payments required by subsection 7b71 or any early purchase option amount provided in the rental-purchase agreement1 as applicable4 7#b7 ,rule of construction ,a requirement that the consumer pay an unpaid late charge or other fee that is past due shall not constitute an additional fee or charge for purposes of this subsection4 7d7 ,transfer of ownership rights ,upon payment by the consumer of all payments necessary to acquire ownership under subsection 7b7 or any early purchase option amount provided in the rental-purchase agreement1 as appropriate1 the merchant shall-- 7#a7 deliver to the consumer1 or mail to the consumer's last known address1 such documents or other instruments1 which the ,commission has determined1 by regulation1 are necessary to acknowledge full ownership by the consumer of the property acquired pursuant to the rental-purchase agreement2 and 7#b7 transfer to the consumer the unexpired portion of any warranties provided by the manufacturer1 distributor1 or seller of the property1 which shall apply as if the consumer were the original purchaser of the property1 except where such transfer is prohibited by the terms of the warranty4 #i4 ,prohibited provisions ,a rental-purchase agreement may not contain-- 7#a7 a confession of judgment2 7#b7 a negotiable instrument2 7#c7 a security interest or any other claim of a property interest in any goods1 except those goods1 the use of which is provided by the merchant pursuant to the rental-purchase agreement2 7#d7 a wage assignment2 7#e7 a provision requiring the waiver of any legal claim or remedy created by this ,act or other provision of ,federal or ,state law2 7#f7 a provision requiring the consumer1 in the event that the property subject to the rental-purchase agreement is lost1 stolen1 damaged1 or destroyed1 to pay an amount in excess of the least of-- 7,a7 the fair market value of the property1 as determined by the ,commission1 by regulation2 7,b7 any early purchase option amount provided in the rental-purchase agreement2 or 7,c7 the actual cost of repair1 as appropriate2 7#g7 a provision authorizing the merchant1 or a person acting on behalf of the merchant-- 7,a7 to enter the consumer's dwelling or other premises without obtaining the consumer's consent2 or 7,b7 to commit any breach of the peace in connection with the repossession of the rental property or the collection of any obligation or alleged obligation of the consumer arising out of the rental-purchase agreement2 7#h7 a provision requiring the purchase of insurance or liability damage waiver to cover the property that is the subject of the rental-purchase agreement1 except as permitted by the ,commission1 by regulation2 or 7#i7 a provision requiring the consumer to pay more than #a late fee or charge for an unpaid or delinquent periodic payment1 regardless of the period in which the payment remains unpaid or delinquent1 or to pay a late fee or charge for any periodic payment because a previously assessed late fee has not been paid in full4 #aj4 ,statement of accounts ,upon request of a consumer1 a merchant shall provide a statement of the consumer's account4 ,if a consumer requests a statement for an individual account more than #d times in any #ab-month period1 the merchant may charge a reasonable fee for the additional statements4 #aa4 ,renegotiations and extensions 7a7 ,renegotiations ,with respect to any rental-purchase agreement1 a renegotiation occurs when the agreement is satisfied and replaced by a new agreement undertaken by the same consumer4 ,a renegotiation requires new disclosures in accordance with this ,act1 except as provided in subsection 7c74 7b7 ,extensions ,with respect to any rental-purchase agreement1 an extension is an agreement by the consumer and the merchant1 to continue an existing rental-purchase agreement beyond the original end of the payment schedule1 but does not include a continuation that is the result of a renegotiation4 7c7 ,exceptions ,new disclosures under this ,act are not required in connection with a rental-purchase agreement for the following events1 even if the event meets the definition of a renegotiation or an extension3 7#a7 ,a reduction in payments4 7#b7 ,a deferment of #a or more payments4 7#c7 ,the extension of a rental-purchase agreement4 7#d7 ,the substitution of property with property that has a substantially equivalent or greater economic value1 provided the rental-purchase cost does not increase4 7#e7 ,the deletion of property in a multiple-item agreement4 7#f7 ,a change in rental period1 provided the rental-purchase cost does not increase4 7#g7 ,an agreement resulting from a court proceeding4 7#h7 ,any other event described in regulations prescribed by the ,commission4 #ab4 ,point-of-rental disclosures 7a7 ,in general ,for any item of property or set of items displayed or offered for rental-purchase1 the merchant shall display on or next to the item or set of items a card1 tag1 or label that clearly and conspicuously discloses-- 7#a7 a brief description of the property2 7#b7 whether the property is new or used2 7#c7 the cash price of the property2 7#d7 the amount of each rental payment2 7#e7 the total number of rental payments necessary to acquire ownership of the property2 and 7#f7 the rental-purchase cost4 7b7 ,form of disclosure 7#a7 ,in general ,a merchant may make the disclosures required by subsection 7a7 in the form of a list1 catalog1 or electronic facsimile of the card1 tag1 or label which is readily available to the consumer at the point of rental if the merchandise is not displayed in the merchant's showroom or if displaying a card1 tag1 or label would be impractical due to the size of the merchandise4 7#b7 ,clearly and conspicuously ,as used in this section1 the term clearly and conspicuously means that information required to be disclosed to the consumer shall appear in a type size1 prominence1 and location as to be noticeable1 readable1 and comprehensible to an ordinary consumer4 #ac4 ,rental-purchase advertising 7a7 ,in general ,if an advertisement for a rental-purchase transaction refers to or states the amount of any payment for any specific item or set of items1 the merchant making the advertisement shall also clearly and conspicuously state in the advertisement1 for the item or set of items advertised-- 7#a7 that the transaction advertised is a rental-purchase agreement2 7#b7 the amount1 timing1 and total number of rental payments necessary to acquire ownership under the rental-purchase agreement2 7#c7 the amount of the rental-purchase cost2 7#d7 that1 to acquire ownership of the property1 the consumer must pay the rental-purchase cost plus applicable taxes2 and 7#e7 whether the stated payment amount and advertised rental-purchase cost is for new or used property4 7b7 ,prohibition ,an advertisement for a rental-purchase agreement shall not state or imply that a specific item or set of items is available at specific amounts or terms1 unless the merchant usually and customarily offers1 or will offer1 the item or set of items at the stated amounts or terms4 7c7 ,clearly and conspicuously 7#a7 ,in general ,for purposes of this section1 the term clearly and conspicuously means that required disclosures shall be presented in a type1 size1 shade1 contrast1 prominence1 location1 and manner1 as applicable to different mediums for advertising1 so as to be readily noticeable and comprehensible to the ordinary consumer4 7#b7 ,regulatory guidance ,the ,commission shall prescribe regulations on principles and factors to meet the clear and conspicuous standard1 as appropriate to print1 video1 audio1 and computerized advertising1 reflecting the principles and factors typically applied in each such medium by the ,commission4 7#c7 ,limitation ,nothing contrary to1 inconsistent with1 or in mitigation of1 the disclosures required by this section shall be used in any advertisement in any medium1 and no audio1 video1 or print technique shall be used that is likely to obscure or detract significantly from the communication of the disclosures4 #ad4 ,enforcement by ,commission 7a7 ,unfair or deceptive acts or practices ,a violation of a provision of this ,act or a rule or regulation prescribed pursuant to this ,act shall be treated as a violation of a rule defining an unfair or deceptive act or practice described under section #ah7;a77#a77;,b7 of the ,federal ,trade ,commission ,act 7#ae ,u4,s4,c4 #eg;a7a77#a77;,b774 7b7 ,powers of ,commission 7#a7 ,in general ,except as provided in paragraph 7#c71 the ,commission shall enforce this ,act in the same manner1 by the same means1 and with the same jurisdiction1 powers1 and duties as though all applicable terms and provisions of the ,federal ,trade ,commission ,act 7#ae ,u4,s4,c4 #da et seq47 were incorporated into and made a part of this ,act4 7#b7 ,privileges and immunities ,except as provided in paragraph 7#c71 any person who violates this ,act shall be subject to the penalties and entitled to the privileges and immunities provided in the ,federal ,trade ,commission ,act 7#ae ,u4,s4,c4 #da et seq474 #ae4 ,regulations 7a7 ,in general 7#a7 ,commission action ,the ,commission shall prescribe regulations as necessary to carry out this ,act4 7#b7 ,content ,regulations required by this subsection may contain such additional requirements1 classifications1 differentiations1 or other provisions1 and may provide for such adjustments and exceptions for all or any class of transactions1 as in the judgment of the ,commission are necessary or proper to effectuate the purposes of this ,act1 to prevent circumvention or evasion thereof1 or to facilitate compliance therewith4 7b7 ,model disclosure forms 7#a7 ,in general ,the ,commission may publish model disclosure forms and clauses for common rental-purchase agreements to facilitate compliance with the disclosure requirements of this ,act and to aid the consumer in understanding the transaction by utilizing readily understandable language to simplify the technical nature of the disclosures4 7#b7 ,considerations ,in devising model forms under this subsection1 the ,commission shall consider the use by merchants of data processing or similar automated equipment4 7#c7 ,voluntary use of model forms ,nothing in this ,act may be construed to require a merchant to use any model form or clause prescribed by the ,commission under this section4 7#d7 ,presumption ,a merchant shall be deemed to be in compliance with the requirement to provide disclosure under section #e7;a71 if the merchant-- 7,a7 uses any appropriate model form or clause as published by the ,commission under this section2 or 7,b7 uses any such model form or clause and changes it by-- 7i7 deleting any information which is not required by this ,act2 or 7ii7 rearranging the format1 if in making such deletion or rearranging the format1 the merchant does not affect the substance1 clarity1 or meaningful sequence of the disclosure4 #af4 ,effective date of regulations 7a7 ,in general ,any regulation prescribed by the ,commission under this ,act1 or any amendment or interpretation thereof1 shall not be effective before the ,october #a that follows the date of publication of the regulation in final form by at least #f months4 7b7 ,authority ,to extend time ,the ,commission may1 at its discretion-- 7#a7 lengthen the period of time described in subsection 7a7 to permit merchants to adjust to accommodate new requirements2 or 7#b7 shorten that period of time1 if the ,commission makes a specific finding that such action is necessary to comply with the findings of a court or to prevent unfair or deceptive practices4 7c7 ,early compliance authorized ,notwithstanding the time periods established under subsection 7a7 or 7b71 a merchant may comply with any newly prescribed disclosure requirement prior to such established date4 #ag4 ,relation to other laws 7a7 ,relation to ,state law 7#a7 ,no effect on consistent ,state laws ,except as provided in subsection 7b71 this ,act does not annul1 alter1 or affect in any manner the meaning1 scope1 or applicability of the laws of any ,state relating to rental-purchase agreements1 except to the extent that those laws are inconsistent with any provision of this ,act1 and then only to the extent of the inconsistency4 7#b7 ,determination of inconsistency ,upon its own motion or upon the request of an interested party1 which is submitted in accordance with procedures prescribed in regulations of the ,commission1 the ,commission shall determine whether any such inconsistency exists4 ,if the ,commission determines that a term or provision1 of a ,state law is inconsistent1 merchants located in that ,state need not follow such term or provision and shall incur no liability under the law of that ,state for failure to follow such term or provision1 notwithstanding that such determination is subsequently amended1 rescinded1 or determined by judicial or other authority to be invalid for any reason4 7#c7 ,greater protection under ,state law ,except as provided in subsection 7b71 for purposes of this section1 a term or provision of a ,state law is not inconsistent with the provisions of this ,act if the term or provision affords greater protection and benefit to the consumer than the protection and benefit provided under this ,act1 as determined by the ,commission1 on its own motion or upon the petition of any interested party4 7b7 ,state laws relating to characterization of transaction ,notwithstanding subsection 7a71 this ,act shall supersede any provision of ,state law1 to the extent that such law-- 7#a7 regulates a rental-purchase agreement as a security interest1 credit sale1 retail installment sale1 conditional sale or any other form of consumer credit1 or that imputes to a rental-purchase agreement the creation of a debt or extension of credit2 or 7#b7 requires the disclosure of a percentage rate calculation1 including a time-price differential1 an annual percentage rate1 or an effective annual percentage rate4 7c7 ,relation to ,federal ,trade ,commission ,act ,no provision of this ,act shall be construed as limiting1 superseding1 or otherwise affecting the applicability of the ,federal ,trade ,commission ,act 7#ae ,u4,s4,c4 #da et seq47 to any merchant or rental-purchase transaction4 #ah4 ,effect on ,government agencies ,no civil liability or criminal penalty under this ,act may be imposed on the ,united ,states or any of its departments or agencies1 any ,state or political subdivision1 or any agency of a ,state or political subdivision4 #ai4 ,compliance date ,compliance with this ,act and regulations issued under this ,act is not required until #f months after the date of enactment of this ,act4 ,in any case1 merchants may comply with this ,act at any time after such date of enactment4