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Phillips Esq.
Phillips Esq., Attorney-at-Law
Category: Business Law
Satisfied Customers: 19021
Experience:  B.A.; M.B.A.; J.D.
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Small internet business offering consumer credit in two ways

Customer Question

Small internet business offering consumer credit in two ways

#1 open end revolving which we do ourselves
#2 retail installment contracts as prescribed by third party finance companies when we do not finance ourselves
Does regulation z apply to both kinds of transactions equally
Submitted: 5 years ago.
Category: Business Law
Expert:  Phillips Esq. replied 5 years ago.
Thank you for giving me the opportunity to assist you. I encourage you to ask me for clarification, if you are not clear with my Answer.

Question:
Small internet business offering consumer credit in two ways

#1 open end revolving which we do ourselves
#2 retail installment contracts as prescribed by third party finance companies when we do not finance ourselves
Does regulation z apply to both kinds of transactions equally

Response: Yes, in both scenarios the creditor must clearly disclose the terms of credit to the consumer. See Regulation Z, 6500 Consumer Protection Part 226 Subpart A Section 226.1(c) and Subpart C Sections 226.17 to 226.24:

http://www.fdic.gov/regulations/laws/rules/6500-1400.html#fdic6500226.1
Customer: replied 5 years ago.
I am sure you know I cannot possibly read & understand reg Z
BUT our customers seem to understand
over 10,000 customers in 15 years with NO serious complaints
Rating A at local BBB
BUT I fear that because I use wrong type size
Don't have proper discalimer next to an advertised price I get HAMMERED by some consumer protection agency
Is there a major points check list?
A readers digest version so that I can be in reasonable compliance without going out of business because of excessive legal bills of questionable value
Expert:  Phillips Esq. replied 5 years ago.
I am not sure how to condense the Regulation Z for you into a checklist. So, I will opt out and give another Expert the opportunity to futher assist you.
Customer: replied 5 years ago.
Forgive me BUT I am a frustrated old man

Many times when I read a government regulation there ia an ammended version like cliff notes so you can know IF this specidic regulation applies to you OR what part might
I have NO unresolved complaints IF a customer complains to me. I fear a consumer advocate who does not want me to resolve the complaint and rather punish me or put me out of business for some technical isssue or misunderstanding that I could have resoved easily if given the opportunity

Is there a check sheet, cliff notes? OR
Is it safe to say IF a customer understands the true cost of credit and acknowledges that at the time he signs the contract i am reasonably safe with regards to regulation Z?
Or is it I must have all admonitions in a presribed type size regardless of what the customer signs
Is it technical or is compliance with the spirit of truth in lending sufficient?

I will pay $100 for a good answer