Consumers Union of the U.S., Inc. v. Federal Reserve Board

Opinion for the Court filed by Circuit Judge SILBERMAN.

SILBERMAN, Circuit Judge:

This appeal from the district court challenges regulations issued by the Board of Governors of the Federal Reserve System implementing the amendments to the Truth in Lending Act (“TILA”) concerning open-end home equity loans. Appellant asserts that the regulations are inconsistent with the statute. We reject the majority of appellant’s contentions but remand to the Board on two issues.

I

Open-end home equity loans (“HELs”) are financial instruments whose popularity among ordinary consumers skyrocketed in the last…