AMERICAN FINANCIAL SERVICES ASSOCIATION, Petitioner,
v.
FEDERAL TRADE COMMISSION, Respondent,
Silas Brown, et al., American Conference of Uniform Consumer Credit Code States, Intervenors.
The SOUTH CAROLINA DEPARTMENT OF CONSUMER AFFAIRS, Petitioner,
v.
FEDERAL TRADE COMMISSION, Respondent,
American Conference of Uniform Consumer Credit Code States, American Financial Services Association, Department of Commerce of the State of Montana, Intervenors.
United States Court of Appeals, District of Columbia Circuit.https://leagle.com/images/logo.png
Argued February 22, 1985.
Decided July 12, 1985.
Attorney(s) appearing for the Case
David H. Remes, Washington, D.C., with whom William H. Allen, Washington, D.C., was on the brief, for petitioner/intervenor American Financial Services Ass'n in Nos. 84-1081 and 84-1167.
Steven W. Hamm, Columbia, S.C., with whom Philip S. Porter, Pickens, S.C., and J.M. Edouard Mille, Columbia, S.C., were on the brief, for petitioner South Carolina Dept. of Consumer Affairs in No. 84-1167. Philip S. Porter, Pickens, S.C., and J.M. Edouard Mille, Columbia, S.C., were also on the brief for intervenor American Conference of Uniform Consumer Credit Code States in Nos. 84-1081 and 84-1167.
Ernest J. Isenstadt, Asst. General Counsel, F.T.C., with whom Howard E. Shapiro, Deputy General Counsel, and Lawrence DeMille-Wagman, F.T.C., Washington, D.C., were on the brief, for respondent in Nos. 84-1081 and 84-1167.
J. Alan Galbraith, Washington, D.C., for intervenors Silas Brown, et al. in No. 84-1081. Charles Hill, Washington, D.C., entered an appearance for intervenors.
Francis X. Bellotti, Boston, Mass., was on the brief, for Com. of Mass., et al., amicus curiae, in Nos. 84-1081 and 84-1167. Rex Butler, Anchorage, Alaska, entered an appearance for amicus curiae in No. 84-1081.
Edwin Lloyd Pittman, Jackson, Miss., was on the brief for the Commissioner of Banking and Consumer Finance of the State of Miss., amicus curiae, in Nos. 84-1081 and 84-1167.
R. Stuart Broom, Washington, D.C., was on the brief for Nat. Ass'n of Consumer Credit Administrators, amicus curiae, in Nos. 84-1081 and 84-1167.
Before TAMM, WALD and EDWARDS, Circuit Judges.
United States Court of Appeals, District of Columbia Circuit.
Opinion for the Court filed by Circuit Judge WALD.
Dissenting opinion filed by Circuit Judge TAMM.
WALD, Circuit Judge:
In these consolidated cases, the petitioners, American Financial Services Association (AFSA) and South Carolina Department of Consumer Affairs (SCDCA) seek review of the Federal Trade Commission's ("the FTC" or "the Commission") Trade Regulation Rule on Credit Practices ("the Credit Practices...
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