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1.5.1 Introduction

One of the complications of handling Truth in Lending Act issues is the number of sources of law. These include TILA itself, the Consumer Financial Protection Bureau’s Regulation Z, which implements the Act, the Official Interpretations of Regulation Z, legislative193 and regulatory194 history, and case law,195 which must be divided into post-Simplification cases and pre-Simplification cases. Finally, there are treatises and law review articles. The usefulness and authority of these various sources of law are discussed in the following subsections. Retroactivity of amendments to the Act, Regulation Z, and the official interpretations is discussed at § 12.5.6, infra.


  • 193 {193} TILA’s legislative history is archived in the companion materials accompanying the online version of this treatise under the heading “Primary Sources.”

  • 194 {194} To track additions to and changes over time in Regulation Z and the Official Interpretations to Regulation Z and the rationale provided for each change, review Appendix B Historical Chart of Regulation Z and Official Interpretations, available only online as a digital appendix to this treatise.

  • 195 {195} See Madel v. GMAC Mortgage Corp., 2004 WL 4055247 (Bankr. E.D. Wis. Nov. 8, 2004) (reciting all of these as sources of law for a TILA case).