Consumer Credit Regulation: 5.11.1 Developing a System for Analyzing Consumer Credit Issues
Generally, clients do not complain to their attorneys about specific usury issues. For example, it would be fairly unusual for a client to waltz into a law office saying, “I think the bank overcharged me $0.39 for credit insurance which is arguably interest and possibly a usury violation.” More likely a client will appear after the transaction has gone sour for one reason or another. It then becomes the attorney’s job to analyze the facts and issues relevant to the transaction.