"Schumer Box" Disclosure Not "Clear and Conspicuous" As A Matter Of Law


Question: Is a Schumer box disclosure describing an APR as "fixed," linked with an asterisk to a paragraph printed just below the Schumer box stating the APR could be increased under three conditions, and also coupled with language, further down the same page, providing the customer would be bound by the terms of the bank's customer agreement (which permitted the bank to change rates at any time) "clear and conspicuous" under the Truth in Lending Act?

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