Getting an adverse report from a banking department can often feel disruptive. Once the corrective measures are put in place to the satisfaction of the regulator, you should be able to feel more sure about implementing protective policies and procedures. Sometimes, practices change over time without updating the process document, or procedures are not properly followed.
Regulation Z, the implementing regulation of the Truth-in-Lending Act (TILA), imposes restrictions on the advertising of closed-end consumer credit plans. I can’t tell from your question what aspect of Regulation Z caused your regulator to issue particular adverse findings relating to prohibited acts or practices. However, I think it is valuable to ensure we’re clear about certain aspects that could factor into the analysis.
As provided in Regulation Z, all advertisements are subject to the same “clear and conspicuous” standard Regulation Z applies to all disclosures. In July 2008, the Federal Reserve Board amended Regulation Z to expand its standards for this clear and conspicuous standard. Still, TILA and Regulation Z do not prescribe specific rules for the format, such as type size or placement, of the necessary closed-end disclosures, other than the format requirements that apply to the disclosure of rates and payments.
