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Effective July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (TILA) and the Consumer Leasing Act (CLA) apply to consumer credit transactions and consumer leases up to $50,000, compared with $25,000 currently.
The Consumer Leasing Act (CLA) was enacted in 1976 as part of the Truth in Lending Act (TILA) to protect lessees from unclear or deceiving statements and advertisements by lessors.
Lease contracts must provide full disclosure of the following facts: That the transaction is a lease. A description of the leased vehicle. The capitalized amount. The full term of the lease.
A.Messages in newspapers, magazines, leaflets, catalogs, and fliers;Messages on radio, television and public address systems;Direct mail;Telephone solicitations;Signs or displays; and.Online information, such as the Internet.
The regulation covers topics such as:Disclosure of lease schedule and payments. Early termination notices. Purchase option disclosures. Lease renegotiations, extensions, and assumptions.
Disclosures required by Federal Reserve Board Regulation M that must be grouped together and separated from other information in the lease documents.
Consumer leases may include:Automobile leases, Furniture leases, & Other personal property leases. Closed-end (walk-away) leases. Open-end leases.
For an advertisement accessed by the consumer in electronic form, the required disclosures may be provided to the consumer in electronic form in the advertisement, without regard to the consumer consent or other provisions of the E-Sign Act.
The Act requires that certain lease costs and terms be disclosed, imposes limitations on the size of penalties for delinquency or default and on the size of residual liabilities, and requires certain disclosures in lease advertising.
Regulation M. (a) General rule. An advertisement for a consumer lease may state that a specific lease of property at specific amounts or terms is available only if the lessor usually and customarily leases or will lease the property at those amounts or terms.