Jones v. Community Loan & Investment Corp.

526 F.2d 642, 1976 U.S. App. LEXIS 13061
CourtCourt of Appeals for the Fifth Circuit
DecidedJanuary 30, 1976
DocketNos. 74-3586, 74-3975, 74-4183
StatusPublished
Cited by13 cases

This text of 526 F.2d 642 (Jones v. Community Loan & Investment Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Community Loan & Investment Corp., 526 F.2d 642, 1976 U.S. App. LEXIS 13061 (5th Cir. 1976).

Opinion

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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Bluebook (online)
526 F.2d 642, 1976 U.S. App. LEXIS 13061, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-community-loan-investment-corp-ca5-1976.