CONCEPTS AND TRAINING NOTES 2026
◉ (True/False) In cases in which the lease is not regulated by the
CLA or Reg. M, best practices dictate completing the transaction as if
it was governed by the CLA and Reg. M. Answer: True
◉ What are the three components of a lease payment? Answer: 1.
Depreciation
2. Amortized Amounts
3. Rent Charge
◉ You may be able to remedy a violation of the CLA or Reg. M if,
within _______ days of discovering an error (and before being sued by
the customer for the error), you notify the customer of the error and
make the necessary adjustments to the customer's account to assure
that the customer will not be required to pay an amount in excess of
the charge actually disclosed or the dollar equivalent of the APR
actually disclosed, whichever is less. Answer: 60
◉ (True/False) Almost all states have laws that require disclosures
above and beyond the disclosures already required by Regulation M
that are just as binding as the federal rules. Answer: True
,◉ What does the following describe? "The amount determined at
the inception of the lease to be the value of the vehicle at the end of
the agreement." This figure is subtracted from the adjusted
capitalized cost to determine the amount of depreciation in the
value of the vehicle that will occur over the term of the lease.
Answer: Residual Value
◉ (True/False) The CLA and Reg. M disclosures must be made prior
to consummation in a form the lessee can keep. Answer: True
◉ (True/False) When completing the "Amount Due at Lease Signing
or Delivery" section of a lease agreement, it's permissible to enter a
single amount that represents the total of the various amounts that
will be due and payable when the contract is executed. Answer: False
◉ Which act does Regulation M implement? Answer: Consumer
Leasing Act
◉ A lease agreement in which the lessee's liability at the end of term
is limited to excessive wear and excess mileage charges is a(n) _______
lease. Answer: Closed-end
◉ Unlike an installment sale agreement, a lease agreement lists the
_______ on the left and the _______ on the right. Answer: Lessor, Lessee
,◉ The _______ includes any amounts, such as the net value of a trade-
in, factory rebate or cash, that reduce the gross capitalized cost.
Answer: Capitalized Cost Reduction
◉ (True/False) According to the Consumer Leasing Act, a lessor may
extend an existing lease without new
disclosures on a month-to-month basis so long as the maximum
term is six months or less. Answer: True
◉ (True/False) A customer wishes to pay for a used car with four
cashier's checks drawn on four different banks in the amounts of
$7,500, $6,800, $3,000, and $8,300. Since none of the checks exceeds
$10,000, the F&I person need not complete IRS / FinCEN Form
8300. Answer: False
◉ A customer buying a new car is paying $5,000 cash down and
owes $7,500 more on the trade-in than was allowed. In this case, the
postings on the installment sale agreement can be: Answer: a. a
downpayment of zero and an additional amount financed of $2,500.
OR
b. a downpayment of $5,000 and an additional amount financed of
$7,500.
◉ The purpose of Regulation Z Answer: To allow people to compare
the cost of credit.
, ◉ Are there any defenses to a civil claim for a violation of TILA or
Reg. Z? Answer: Yes.
1. "bona fide error" defense; and
2. "safe harbor"
◉ Bona fide error defense Answer: A creditor claiming this defense
must show by a "preponderance of evidence" that the violation was
not intentional and resulted from a bona fide error. (Ex., clerical &
calculation errors, computer malfunctions, programming problems
and printing errors.)
◉ Safe Harbor Answer: If the creditor relied in good faith on "any
rule, regulation or interpretation thereof by the Bureau or in
conformity with any interpretation or approval by an official or
employee of the Federal Reserve System duly authorized by the
Bureau to issue such interpretations or approvals under such
procedures as the Bureau may prescribe."
◉ The "lessor" is the ____________. Answer: Dealer
◉ The "lessee" is the ___________. Answer: Consumer