To embed, copy and paste the code into your website or blog: Almost 45 years after the FTC’s Holder Rule and corresponding FTC staff guidance were issued, the FTC has issued a “staff note” in which FTC staff concludes that the TILA exemption for large transactions does not apply to the FTC’s Holder Rule (which is officially titled the “Trade Regulation Rule Concerning Preservation of Consumers’ Claims and Defenses”). The Holder Rule requires sellers that arrange for or offer credit to finance the purchase of consumer goods or services to include a specified “holder notice” in the credit contract. The notice must state that any holder of the contract is subject to all claims and defenses the consumer could assert against the seller of the financed goods or services, with the consumer’s recovery limited to the amount paid by the consumer under the contract.