Should Consumer Disclosures Be Updated?
UCC08-10: In May 2008, the Truth in Lending Act (TIL), Title I of the Consumer Protection Act of 1968 (Public Law 90-321, May 29, 1968), reaches its fortieth birthday. Like many forty year olds, TIL is active and vigorous, if a bit paunchy and cranky, although it is mostly a bit mellower and more settled than in its wilder youth. Nonetheless, upcoming round number birthdays frequently provoke reminiscences, and sometimes calls for reflections or even a roast. In TIL’s case there is no shortage of roast-worthy background material, but an answer to the question what highly visible central feature provides a useful caricature for roasting actually is quite simple. Nothing better typifies TIL, or provokes more discussion and gnashing of teeth, than its requirement for disclosing the “Annual Percentage Rate,” widely known and loved as the “APR…”