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If a bank received notice from the FDIC that it did not comply with Truth in Lending Act disclosure requirements but the finance charge was overstated and annual percentage rate was within tolerances, how should the bank rebut the notice? – IBA Compliance Connection

IBA Compliance Connection

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If a bank received notice from the FDIC that it did not comply with Truth in Lending Act disclosure requirements but the finance charge was overstated and annual percentage rate was within tolerances, how should the bank rebut the notice?

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If  the finance charge was overstated in the original disclosure, then the disclosure should be considered accurate under the TILA regulations. 12 CFR  1026.18(d)(1)(ii). Your written rebuttal should include the regulation and an explanation of why you believe the FDIC should reconsider its conclusion that the disclosure was inaccurate.