MEMORANDUM AND ORDER
GESELL, District Judge.
Upon consideration of plaintiff's motion for summary judgment, the statement of points and authorities in support thereof and in opposition thereto, and after full hearing, the Court makes the following findings:
Defendant is a creditor as defined by the Truth in Lending Act, 15 U.S.C. § 1602(f) and Regulation Z, § 226.2(s), and the six transactions at issue are "credit sales." 15 U.S.C. § 1602(g); Regulation Z, § 226.2(t). The Court finds that the transactions were not under an "open end credit" plan, see Regulation Z, § 226.2(x), and therefore the defendant was required to make the Truth in Lending disclosures listed in Regulation Z, § 226.8.
The Court finds that defendant violated Regulation Z, § 226.8(b)(5), in each transaction by failing to provide a clear description of the property subject to a security interest. The disclosure was misleading and unclear in two respects. First, the face of the contract which contains the Truth in Lending disclosure statement does not disclose all the secured property. The face of the contract identifies only the most recently purchased property as subject to a security interest. No specific statement on the front side directs pointed attention to the further and more crucial security statement on the reverse side.
Second, the cross collateral clause on the reverse side of the contract does not clearly identify the collateral carried over from previous transactions. At the foot of the first or front page the following appears:
The terms of this contract are contained on both sides of this page.