CLARK, Circuit Judge:
The appeals in these consolidated Regulation Z Truth-in-Lending cases turn on whether the statutory loan fees imposed pursuant to Georgia law were required to be disclosed as “prepaid finance charges.” To resolve the issue we must harmonize the federal statutory scheme, its implementing regulations and the applicable Georgia statutes. Because these loan fees were fully earned at the time the loans were made, Regulation Z required that they be disclosed as “prepaid” to meaningfully inform the borrower of the prepaid nature of such fees. This is true despite the fact that the loan companies effected the collection of such fees by adding them to the other amounts of credit extended and allowed repayment to be made over the life of the loan. The judgments appealed from which approved notes that failed to disclose the “prepaid” status of such loan fees are reversed.
The instant actions seeking statutory damages, costs and attorneys’ fees were brought under the Consumer Credit Protection Act, 15 U.S.C. § 1640. Each action alleges various violations of the Act in connection with its subject loan. One assertion common to all causes is the contention that the loan or service fees charged under Georgia law were required by Regulation Z,-12 C.F.R. Part 226, to be labeled as a “prepaid finance charge” and that for lack of proper labeling the lenders are liable to the borrowers for the Act’s statutory damages. Our view that the contention is correct makes the issue dispositive in all appeals.
Regulation Z defines “credit” as the right granted by a lender to a customer to defer payment of debt, or to incur debt and defer its payment. 12 C.F.R. § 226.2(7). In the case of loans such as the ones involved in the instant actions, Regulation Z requires that any penalty charge for prepayment be described. 12 C.F.R. § 226.8(b)(6). In addition, it requires disclosure of the amount of credit which will be paid to the customer, or for his account to another person, under the term “amount financed.” This latter requirement is subject to an express proviso which is the fulcrum of the present appeals. It mandates that “[a]ny finance charge paid separately, in cash or other[644]*644wise, directly or indirectly to the creditor or withheld by the creditor from the proceeds of the credit extended” shall be excluded from the “amount financed” and disclosed as a “prepaid finance charge.” 12 C.F.R. § 226.8(d) and (e)(1)-1
On August 31, 1973, the Board issued an interpretative amendment to Regulation Z to make it clear “that the typical ‘add-on’ or ‘discount’ charge or other precomputed finance charge need not be labeled a ‘prepaid’ finance charge.” (emphasis added). In essence, this interpretative amendment advised that “add-on, discount or other precomputed finance charges which are reflected in the face amount of the debt instrument as part’of the customer’s obligation” should be excluded from the “amount financed” and did not require labeling as “prepaid.” The Board’s amendatory language reasoned: “The concept of prepaid finance charges was adopted to insure that the ‘amount financed’ reflected only that credit of which the customer had the actual use.” 38 Fed.Reg. 23513.2
[645]*645Against this background of federal statute and regulation, we consider the details of the Georgia loans involved in the instant actions. The plaintiff individuals in each of the consolidated cases borrowed money from different finance companies. The defendant lenders charged the borrowers the maximum 8% per annum rate of interest permitted by Georgia law and also charged the maximum “Fee for making loan” permitted by Georgia law. Ga.Code Ann., § 25-315(a) and (b).3 The lenders did not label this loan fee as a “prepaid finance charge.” It was not included in the “amount financed” total shown on the face of the note. However, the fee was included in the total amount on which the maximum statutory interest charge was computed. The loan fee, the interest so calculated, and the “amount financed” were then totaled and divided into equal installments payable over the life of the loan. Each note contained different prepayment provisions,4 but none provided for the refund of any part [646]*646of the loan or service fee except as absolutely necessary to avoid the usury provision of Georgia law.5
The definitive opinion by the district court on the proper classification of the Georgia loan fee was written in Slatter v. Aetna Finance Co., 377 F.Supp. 806 (N.D.Ga.1974).6 There the court distinguished its prior holding in Grubb v. Oliver Enterprises, Inc., 358 F.Supp. 970 (N.D.Ga.1972), which required the Georgia loan fee to be characterized as a “prepaid finance charge.” The distinction was based upon what Slatter characterized as a difference in the method of fiscal disbursements and accounting followed in the two transactions. Grubb involved a $55.94 loan which was refinanced 4 months after it was made by a second loan of the same amount. The Grubb court stated that the loan fee there was collected at the time the loan was made and was not refundable except as required by statute in connection with a refinancing, and held such a fee had to be labeled “prepaid” to comply with Regulation Z.7 Slatter reasoned that Grubb involved a loan fee “actually withheld at the time of the consummation of the loan,” whereas Slatter’s loan fee had been added to the amount financed along with the interest charged to Slatter and the total had been divided by the number of monthly payments involved.8 This, said the Slatter court, constituted the loan fee a charge in the nature of an add-on finance charge within the meaning of the Reserve Board’s August 23, 1973 amendment.
The court in Slatter was persuaded that the difference in language used by the Georgia legislature in authorizing interest charges under § 25-315(a) and in authorizing loan fees under § 25-315(b)9 was intended to extend to lenders an option of “receiving or collecting the loan fee ‘at the time the loan is made’ or of merely charging the loan fee at the time the loan is made and adding it to the principal amount for collection along with the loan payments.” Its reasoning went that since the statute made it mandatory to use the add-on method of computing interest on loans for periods greater than 18 months and did not mandate any method for collection of the loan fee, the latter section was permissive. Thus, it read the language permitting a lender to “charge, contract for, receive or collect at the time the loan is [647]*647made, a [loan] fee” as allowing the lender two alternatives. It could charge, contract for, or receive the loan fee in any manner it wished or it could collect the fee at the time the loan was made. Not only is this construction at odds with the catch line title of the loan fee paragraph, which is “FEE FOR MAKING
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CLARK, Circuit Judge:
The appeals in these consolidated Regulation Z Truth-in-Lending cases turn on whether the statutory loan fees imposed pursuant to Georgia law were required to be disclosed as “prepaid finance charges.” To resolve the issue we must harmonize the federal statutory scheme, its implementing regulations and the applicable Georgia statutes. Because these loan fees were fully earned at the time the loans were made, Regulation Z required that they be disclosed as “prepaid” to meaningfully inform the borrower of the prepaid nature of such fees. This is true despite the fact that the loan companies effected the collection of such fees by adding them to the other amounts of credit extended and allowed repayment to be made over the life of the loan. The judgments appealed from which approved notes that failed to disclose the “prepaid” status of such loan fees are reversed.
The instant actions seeking statutory damages, costs and attorneys’ fees were brought under the Consumer Credit Protection Act, 15 U.S.C. § 1640. Each action alleges various violations of the Act in connection with its subject loan. One assertion common to all causes is the contention that the loan or service fees charged under Georgia law were required by Regulation Z,-12 C.F.R. Part 226, to be labeled as a “prepaid finance charge” and that for lack of proper labeling the lenders are liable to the borrowers for the Act’s statutory damages. Our view that the contention is correct makes the issue dispositive in all appeals.
Regulation Z defines “credit” as the right granted by a lender to a customer to defer payment of debt, or to incur debt and defer its payment. 12 C.F.R. § 226.2(7). In the case of loans such as the ones involved in the instant actions, Regulation Z requires that any penalty charge for prepayment be described. 12 C.F.R. § 226.8(b)(6). In addition, it requires disclosure of the amount of credit which will be paid to the customer, or for his account to another person, under the term “amount financed.” This latter requirement is subject to an express proviso which is the fulcrum of the present appeals. It mandates that “[a]ny finance charge paid separately, in cash or other[644]*644wise, directly or indirectly to the creditor or withheld by the creditor from the proceeds of the credit extended” shall be excluded from the “amount financed” and disclosed as a “prepaid finance charge.” 12 C.F.R. § 226.8(d) and (e)(1)-1
On August 31, 1973, the Board issued an interpretative amendment to Regulation Z to make it clear “that the typical ‘add-on’ or ‘discount’ charge or other precomputed finance charge need not be labeled a ‘prepaid’ finance charge.” (emphasis added). In essence, this interpretative amendment advised that “add-on, discount or other precomputed finance charges which are reflected in the face amount of the debt instrument as part’of the customer’s obligation” should be excluded from the “amount financed” and did not require labeling as “prepaid.” The Board’s amendatory language reasoned: “The concept of prepaid finance charges was adopted to insure that the ‘amount financed’ reflected only that credit of which the customer had the actual use.” 38 Fed.Reg. 23513.2
[645]*645Against this background of federal statute and regulation, we consider the details of the Georgia loans involved in the instant actions. The plaintiff individuals in each of the consolidated cases borrowed money from different finance companies. The defendant lenders charged the borrowers the maximum 8% per annum rate of interest permitted by Georgia law and also charged the maximum “Fee for making loan” permitted by Georgia law. Ga.Code Ann., § 25-315(a) and (b).3 The lenders did not label this loan fee as a “prepaid finance charge.” It was not included in the “amount financed” total shown on the face of the note. However, the fee was included in the total amount on which the maximum statutory interest charge was computed. The loan fee, the interest so calculated, and the “amount financed” were then totaled and divided into equal installments payable over the life of the loan. Each note contained different prepayment provisions,4 but none provided for the refund of any part [646]*646of the loan or service fee except as absolutely necessary to avoid the usury provision of Georgia law.5
The definitive opinion by the district court on the proper classification of the Georgia loan fee was written in Slatter v. Aetna Finance Co., 377 F.Supp. 806 (N.D.Ga.1974).6 There the court distinguished its prior holding in Grubb v. Oliver Enterprises, Inc., 358 F.Supp. 970 (N.D.Ga.1972), which required the Georgia loan fee to be characterized as a “prepaid finance charge.” The distinction was based upon what Slatter characterized as a difference in the method of fiscal disbursements and accounting followed in the two transactions. Grubb involved a $55.94 loan which was refinanced 4 months after it was made by a second loan of the same amount. The Grubb court stated that the loan fee there was collected at the time the loan was made and was not refundable except as required by statute in connection with a refinancing, and held such a fee had to be labeled “prepaid” to comply with Regulation Z.7 Slatter reasoned that Grubb involved a loan fee “actually withheld at the time of the consummation of the loan,” whereas Slatter’s loan fee had been added to the amount financed along with the interest charged to Slatter and the total had been divided by the number of monthly payments involved.8 This, said the Slatter court, constituted the loan fee a charge in the nature of an add-on finance charge within the meaning of the Reserve Board’s August 23, 1973 amendment.
The court in Slatter was persuaded that the difference in language used by the Georgia legislature in authorizing interest charges under § 25-315(a) and in authorizing loan fees under § 25-315(b)9 was intended to extend to lenders an option of “receiving or collecting the loan fee ‘at the time the loan is made’ or of merely charging the loan fee at the time the loan is made and adding it to the principal amount for collection along with the loan payments.” Its reasoning went that since the statute made it mandatory to use the add-on method of computing interest on loans for periods greater than 18 months and did not mandate any method for collection of the loan fee, the latter section was permissive. Thus, it read the language permitting a lender to “charge, contract for, receive or collect at the time the loan is [647]*647made, a [loan] fee” as allowing the lender two alternatives. It could charge, contract for, or receive the loan fee in any manner it wished or it could collect the fee at the time the loan was made. Not only is this construction at odds with the catch line title of the loan fee paragraph, which is “FEE FOR MAKING LOAN,” it stands the grammar used by the Georgia legislature on its head and fails to follow the construction placed on this part of the statute by the courts of Georgia.
Georgia courts have consistently refused to hold the maximum interest rate to be usurious where that interest rate was calculated on the total of all amounts financed plus a loan fee which had been added in with all other charges and disbursements and collected over the life of a loan. Georgia’s reasoning was that the interest charge calculated in this fashion was not rendered usurious even where the loan fee was repaid in installments because the fee was due at the time the transaction originated and was a fee collected “for making the loan” (emphasis in the original). Robbins v. Welfare Finance Corp., 95 Ga.App. 90, 96 S.E.2d 892, 896 (1957); accord, McDonald v. G.A.C. Finance Corp., 115 Ga.App. 361, 154 S.E.2d 825 (1967).10 This reasoning controls our decision. Deferring collection of the loan fee by adding it on to the other amounts financed does not change its. character as a prepaid fee. Deferring collection of the credit does not cause the credit to be extended at a later date. Regulation Z defines credit as a right the lender grants to the borrower to incur an indebtedness for a loan fee or any other purpose and defer its repayment. The borrower has the use of this credit from the date the loan is made just as he has the actual or constructive use of funds advanced for insurance charges, recording fees and the like.
\Slatter refused to give any weight to the fact that the loan fee was not refundable in the event of prepayment, reasoning that this was a circumstance which occurred after the credit had been extended and was controlled exclusively by the borrower. In light of the Regulation Z requirements that any penalty for prepayment must be described and loss of the loan fee was either not mentioned in these notes or was restricted only to the extent necessary to avoid usury,11 Slatter cannot be squared with the letter or the spirit of meaningful, informed disclosure which the Act and Regulation Z sought to promote.
There can be no doubt that the Slatter court placed great weight on its construction of the Board’s 1973 amendment. It is entirely understandable that the court construed this action to give a finance company the right to omit the “prepaid” characterization of the Georgia loan fee if it added the fee on with the add-on interest and collected it over the period of the loan. When the wording used in the amendatory language is read alone, it is susceptible to the misinterpretation that any finance charge which was added on to the face amount of the obligation and repaid in installments should not be classified as “prepaid.” The problem of interpretation was doubtless compounded by the timing of the ruling, coming as it did after Grubb was decided. However, as the preamble to the amendment makes clear, the Board had reference only to the “typical” add-on charge. When the amendment is read in its total setting— the entire amendment, Regulation Z, the Act, and the Georgia laws which create and authorize the loan fee charge — it be[648]*648comes apparent that the character of this credit cannot be made to depend upon the manner in which the lender may choose to treat it.12
The amendment says that “[t]he concept of prepaid finance charges was adopted to insure that the ‘amount financed’ reflected only that credit of which the customer had the actual use.” Whether the borrower has actual use of credit does not hinge on whether it is disbursed to him. As Regulation Z makes it plain, credit has been extended if monies the borrower must repay have been “paid separately, in cash or otherwise, directly or indirectly to the creditor, ... or withheld by the creditor from the proceeds of the credit extended.” 12 C.F.R. § 226.8(b)(6) and (e)(1).
That the loan fee is to be paid by the borrower to the lender is not even open to question. When it is to be paid is the issue. Every documentary and financial fact indicates that the lender collects the loan fee at the time the credit is extended. As stated, the loan fee was not a refundable charge. Robbins and the other Georgia cases cited above make it plain that the fee is fully earned by the act of extending credit, and that if this were not so, the interest charge as calculated would be usurious. Interest at the maximum statutory rate can only be collected on the full amount of these loan fees in the same manner it was collected on every other part of the “amount financed” because the lender extended credit for this fee in advance. For all of these reasons, this loan fee was an integral part of “that credit of which the customer had the actual use” at the time the note was signed.
The loan fee was required by statute and regulation to be shown as a part of the finance charge, 15 U.S.C. § 1605 (a)(3), 12 C.F.R. § 226.4(a)(3). But showing it as a finance charge without more would be misleading. As a onetime expense due at the outset, the loan fee is different from a typical add-on charge which may later be recovered if not earned or expended with the passage of time over the life of the transaction. The necessity to make this difference plain to the borrower is precisely why Regulation Z requires that the customer be told that this segment of the finance charge is prepaid. If it is to be interpreted in a manner consistent with the Act’s purpose, the amendment cannot be held to have changed this concept, and it did not do so. It must not be held to encompass charges which are in point of economic fact prepaid by credit extended at the outset of the transaction which, to enhance the lender’s income or facilitate the transaction, is deferred in its repayment.
The district court gave controlling weight to the fact that the lender dealt with the fee as an amount added on to the principal and collected in installments over the life of the loan. Such consideration misplaces the add-on form of repayment over the fee’s substance as prepaid credit. The heart requirement of the Consumer Credit Protection Act is disclosure which is meaningful to the borrower. The obvious intent of requiring the labeling of an item as “prepaid” would be to inform the bor[649]*649rower that the charge indicated has already been paid out by him or for his account at the time of the extension of the credit and, as importantly, that it is a charge which will not be returned if the loan is paid off prior to maturity. In every one of these three cases (1) the Georgia loan fee was added to the other items composing the “amount financed” and the lender calculated interest at the maximum statutory rate on the total of these two amounts, and (2) the loan fee was not described as a refundable item in the provision of the note related to calculating prepayment refunds.13
The failure to describe such a finance charge as “prepaid” in these loan instruments entitles plaintiff-appellants to relief under the Act. We need not and do not reach the remaining assignments of error. The several judgments appealed from are reversed and the causes remanded to the district court for further proceedings not inconsistent with this opinion.
Reversed and remanded.