Is the Federal Regulation that Governs the Disclosure of Loan Finance Charges Partially Invalid?
Household Credit Services, Inc. v. Pfennig Docket No. 02-587 From: The Sixth Circuit Case at a Glance Congress enacted the Truth in Lending Act to ensure that consumers receive adequate information regarding credit terms. Pursuant to the authority delegated to it by the TILA, the Federal Reserve Board adopted Regulation Z. With respect to credit card “over the limit” fees, Regulation Z provides that such fees are to be separately disclosed to consumers as “other fees” and not as part of “finance charges.” Now the Supreme Court will decide whether the Sixth Circuit’s invalidation of Federal Reserve Board “Regulation Z” with respect to credit card “over the limit” fees was correct. • Previewed by Michael J. Collins, an attorney with Gibson, Dunn & Crutcher LLP in Denver, Colorado.