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0fficial Staff Commentary Act and Regulation additional administrative enforcement amended amount financed annual percentage rate apply April assessed billing error Board card issuer cardholder cash changes closed-end credit closed-end transactions Commentary provides comply computation Congress consumer advocates consumer credit consumer protection court credit balance credit card credit sale creditor must disclose definition determine disclosure requirements disclosure statement discussion downpayment Electronic Funds Transfer example excluded exempt extension fees finance charge group of goals imposed inconsistent information protection interpretations involved Lending Simplification loan March 31 material disclosures obligation old Act open-end credit plan payable periodic rate periodic statement person premiums rebate Reform Act Regulatory Analysis regulatory structure required disclosures rescission rights result revised Regulation right to rescind Section security interest seller Simplification and Reform Stat statutes total of payments Truth in Lending Truth-in-Lending Act U.S. Supreme Court violations