Consumer Protection Law Commons^™

Good Faith Reliance Upon Federal Reserve Board Staff Opinion Letters: The Circuits Converge, Michael Thomas Kelly

Fordham Urban Law Journal

The Federal Reserve Board (FRB) is the central, single agency for issuing all regulations on credit disclosures. It administers the Truth in Lending Act pursuant to Title I of the Consumer Credit Protection Act. Congress intended the FRB to consolidate all disclosure requirements but the FRB did so in a confusing fashion. It utilizes three different methods of disseminating truth-in-lending information: (1) through the publication of Regulation Z, an administrative code, to prescribe disclosure rules; (2) through interpretations of the rules; and (3) through staff opinion letters. The confusion resulted from disagreements in the applicable law between the three methods. …