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Subjecting Hospitals to Truth in Lending Disclosure Requirements: Bright v. Ball Memorial Hospital

Abstract The federal Truth in Lending Act requires creditors to comply with complex disclosure requirements whenever they engage in consumer credit transactions. In light of procedures adopted by hospitals and health care professionals which permit payment for services over time, there is some question as to whether these groups may be considered creditors within the meaning of the Act and therefore subject to the Act’s disclosure requirements. In Bright v. Ball Memorial Hospital, the Court of Appeals for the Seventh Circuit concluded that a hospital can be a creditor with respect to certain hospital-patient transactions. However, the court found that the defendant had not consummated consumer credit transactions with the plaintiffs and consequently had not violated the Act by failing to make disclosures. This Case Comment contends that although the court correctly determined that a hospital, in certain circumstances, may be subject to the Act, it incorrectly held that Ball Memorial failed to consummate consumer credit transactions with the plaintiffs. This Case Comment also discusses the circumstances under which a hospital should be considered a creditor for purposes of the Truth in Lending Act and recommends that hospitals offering installment payment plans routinely comply with disclosure requirements of the Act.