Credit card disclosures under the Truth in Lending Act may not provide sufficient consumer protection, Federal Reserve Vice Chairman Donald Kohn testified Thursday before the Senate Securities, Insurance and Investment Subcommittee. Based on public comments and "extensive consumer testing," Kohn testified that new rules might be needed to require financial institutions to "make changes to their business models and alter some practices." A marketing firm conducted the consumer testing, which involved trying out different ways of communicating credit card disclosures to consumers to determine what works best. The Federal Reserve also is gathering comments through July 18 concerning possible changes to Regulation Z, which implements the consumer credit protections of the Truth in Lending Act. The proposal is part of a larger effort by the Fed, Office of Thrift Supervision and National Credit Union Administration to implement credit card-industry rules changes on Unfair or Deceptive Acts or Practices under the Federal Trade Commission Act. As of today, the Fed has received an estimated 5,000 comments on those proposed changes. The comment period ends Aug. 4, and the agencies expect the rule changes to go into effect before the end of this year.