Truth in Lending Act

So, I mean, perhaps a good place to start is understanding sort of an overview of what rules and regulations define how these chargeback or how these dispute processes are supposed to work, which I guess now in the age of agentic AI will be very interesting to see how that evolves.

But for example, the Electronic Funds Transfer Act and its implementing reg, reg E, TILA, Truth in Lending Act, reg Z, the card network rules, and so on.

Can you talk a little bit about the basics of how these create the framework of how disputes are handled or are supposed to be handled, I guess I should say?

Yeah, definitely.

Let's turn to how these compare with the traditional consumer requirements.

disclosure requirements that we're all familiar with, truth in lending and so forth.

What's the comparison between the requirements here and the requirements on the consumer side?

So I think the closest consumer analog is probably the Truth in Lending Act disclosures that outline the fees, APR, and so forth.

California and New York have extensive requirements on disclosing the APR, the payment amount, the funding amount, and so forth.

But the issue that is increasingly becoming front and center is how do you take these unique transactions, like a purchase and sale of an invoice, and calculate an APR? Because they're technically a purchase and sale and not a loan.

On the Georgia Real Estate Salesperson Exam, understanding closing roles and settlement documents requires separating federal disclosure rules from Georgia's specific legal requirements.

Under federal rules established by the Consumer Financial Protection Bureau, under the Truth in Lending Act and Real Estate Settlement Procedures Act, known as TRID, lenders must deliver a closing disclosure to the borrower at least three business days prior to loan consummation.

This three-day waiting period gives the borrower adequate time to review final loan terms, interest rates, closing costs, and total cash required at settlement before signing binding loan agreements.

In contrast, the actual conduct of the closing ceremony in Georgia follows distinct state statutory authority.

The reimbursement fee cannot be recovered through overpayment procedures.

The card payment and fee errors follow the error resolution provided procedures of the Truth in Lending Act.

The Electronic Funds Transfers Act.

So you got to go through that process.

Um, in 2020, the CFPB released, I think, their first advisory opinion on earned wage access, which basically said, um, you know, "If you provide earned wage access under these seven pillars," which most did, at least the employer-integrated earned wage access providers, "then we don't consider you a loan.

You're not regulated by TILA or anything like that." And-

The Truth in Lending Act.

Yes, the Truth in Lending Act.

So therefore, there is no loan.

That's kinda the first part.

The second part is, you know, TILA applies to consumer credit that is subject to a finance charge.

Now, as I just said, you know, it's not a loan, so it's not consumer credit.

The aim was to reduce the burden on debtors and identify cases where discharge is appropriate.

Private loans came under the Truth in Lending Act.

Lenders must disclose rates and terms, and borrowers get a three-day cancellation right.

Then, a big one.

So I think what's interesting, I mean, I was also there during the implementation and the rollout of TRID, which is the TILA, it was colloquially called the TILA RESPA Disclosures Disclosure.

Which is the Truth in Lending Act and the Real Estate Procedures Act.

Yeah.

Yeah.

So this brings us back to the history of regulatory environments and consumer psychology.

Decades ago, the Truth in Lending Act actually standardized the term APR to give consumers what seemed like a level playing field.

OK, so it was meant to be helpful.

Right.

They've been quoting these, the FCRAs, under 15 U.S.C. 1681.

Truth in Lending Act, TILA, under 15 U.S.C. 1601.

They've been buying 60-day credit repair packages, waiting by the mailbox, wondering why the credit bureaus keep sending you the same responses.

And what does the response say? Account verified, looking ass.