On December 19, the Consumer Financial Protection Bureau filed four nearly identical lawsuits against lenders based in the Commonwealth of Virginia. Copies of the complaints can be found here, here, here, and here. The complaints allege that the defendants violated the Truth in Lending Act and Consumer Financial Protection Act by charging borrowers for interest, storage, and appraisal without calculating these charges in the annual percentage rate (APR) disclosures. According to the Bureau, the failure to include the information in the APR disclosures rendered the APR calculations inaccurate.
These cases serve as a reminder that the Bureau interprets TILA to require lenders to calculate every charge imposed on the consumer as a part of the APR.