The Bureau’s proposal almost completely abandons the Annual Percentage Rate disclosure. Rather than emphasizing the APR or proposing a substitute, the new forms emphasize the initial interest rate and monthly payment−information that can easily be manipulated by disreputable creditors and that does not accurately disclose the cost of credit. In doing so the CFPB is, essentially, concluding that Congress was wrong in 1968 and that the past 40+ years of experience with TILA have been wasted.