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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