The CFPB states in the amicus brief that the product meets the definition of credit under the federal Truth in Lending Act (“TILA”) because it grants a right to defer payment of a debt.

The opinion also apparently failed to consider all relevant factors in determining what constitutes “credit” under TILA and Regulation Z. Regulatory Uncertainty: The CFPB found that its ...

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) has finalized a new rule ... finance charge disclosure provisions under TILA when they were considered infrequent and extended ...