the SIP Plan did not violate either Regulation G or U. Id. The Borrowers contend that the district court erred in deferring to the McCauley letter. The Trustee responds that it is unclear whether the court gave a heightened level of deference to the letter and, in any event, the court was entitled to defer to its reasoning. Although the court stated that it was giving the staffs opinion substantial weight, other language in its decision implies that it may have deferred to what it believed (mistakenly) was an official opinion of the Federal Reserve Board. The court said that “the Board and its staff ha[ve] primary responsibility for interpreting the Exchange Act and [its] regulations,” citing Ford Motor Credit Co. v. Milhollin, 444 U.S. 555, 565-68, 100 S.Ct. 790, 63 L.Ed.2d 22 (1980) (<HOLDING>), and Revlon, Inc. v. Pantry Pride, Inc., 621
holding that when interpreting a statute or regulation courts must read the provisions of the law as a whole and in context holding that plaintiffs suit was not insubstantial because 1 no prior case existed addressing the regulation being challenged and 2 the allegation that the regulation in question violated federal law was not patently irrational holding that interpretation of regulation by va that conflicted with plain meaning of regulation not entitled to deference holding that deference was appropriate to official staff opinions of federal reserve board interpreting the truth in lending act and regulation z unless demonstrably irrational recognizing that decisions of lower federal courts interpreting federal law are not binding on state courts