SENTINEL FEDERAL S&L v. OFFICE OF THRIFT SUPER.

No. 90-2081.

946 F.2d 85 (1991)

SENTINEL FEDERAL SAVINGS AND LOAN ASSOCIATION OF KANSAS CITY, MISSOURI, Petitioner, v. OFFICE OF THRIFT SUPERVISION, f/k/a Federal Home Loan Bank Board; and, Tim Ryan, Director of the Office of Thrift Supervision, Respondents.

United States Court of Appeals, Eighth Circuit.

Decided October 3, 1991.


Attorney(s) appearing for the Case

Kent Snapp, Kansas City, Mo., argued, for petitioner, Kent Snapp and Karren M. Prasifka, Kansas City, Mo., on the brief.

Richard L. Rennert, Washington, D.C., argued, for respondents, Harris Weinstein, Thomas J. Segal, Elizabeth Moore and Richard L. Rennert, Washington, D.C., on the brief.

Before FAGG and LOKEN, Circuit Judges, and SNEED, Senior Circuit Judge.


LOKEN, Circuit Judge.

The primary issue on this appeal is whether Sentinel Federal Savings & Loan Association violated the Truth in Lending Act, 15 U.S.C. § 1601 et seq. (TILA), by making discounted variable rate loans without disclosing a "composite annual percentage rate" as required by a Federal Reserve Board (FRB) Official Staff Commentary. Concluding that this disclosure was mandatory, the Office of Thrift Supervision (OTS) ordered Sentinel to...

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