Part II of this Note will discuss the facts and holding of Keiran. Part III will examine the legal background and history of TILA and explain recent precedent regarding the specific issue presented in Keiran. In Part IV, this Note will explore the analysis of the majority and dissenting opinions in Keiran. Finally, Part V concludes this Note by criticizing the court’s analysis in the instant decision and contemplating future effects of the decision on borrowers and lenders.

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