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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.