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On January 12, 2010, the Federal Reserve Board approved a final rule (the “Final Rule”) amending Regulation Z (which implements the Truth in Lending Act (TILA)) and the related staff commentary (“Official Staff Interpretations”), in order to implement certain provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (the “Credit CARD Act” or the “Act”) that take effect on February 22, 2010
