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State Lease Disclosures and Regulation M

Written June 11, 1997

Section 429.203(3) of the Wisconsin Statutes requires that a motor vehicle lease contain a number of disclosures in addition to those required by the federal consumer leasing act. However, the disclosures required by sec. 429.203(3), Wis. Stats., are required only if they are not disclosed in the same or substantially similar disclosures under the federal consumer leasing act. The federal disclosure requirements are contained in sec. 213.4 of Regulation M, adopted pursuant to the federal Truth-In-Lending Act.

In the opinion of this department, there is no material difference between the disclosures contained in sec. 429.203(3)(a) - (f), Stats., and comparable disclosures required by federal law. In addition, if both state and federal disclosures were made it could cause the opposite result than was intended by creating confusion and misunderstanding on the part of the consumer. Requiring both disclosures would also cause an undue burden on creditors by requiring redundant disclosures.

Under our authority in sec. 426.104(4), Stats., it is the opinion of this Department that the disclosures required by sec. 429.203(3)(a) - (f), Stats., are substantially similar to those required under the federal consumer leasing act.