Appeals of Material Supervisory Determinations: Guidelines
SARC-98-04 (June 2, 1998)
The Supervision Appeals Review Committee (“Committee”) of
the Federal Deposit Insurance Corporation (“FDIC”), on May 28, 1998,
considered your appeal of two violations of
Section 226.18(d) of Regulation
Z, which implements the Truth in Lending Act, cited in the Compliance
Examination Report (“Report”) as of September 24, 1997.
The Committee, after a review of the material submitted
with the appeal, has concluded that your appeal should be granted. The
Committee reached its determination after due consideration of the
information presented by the Bank and an analysis by its staff. The FDIC
considers this decision a final supervisory determination.
The Committee noted that the Bank has made voluntary
reimbursement of another loan of a similar type, which the Committee viewed
as appropriate in that instance. The Committee also expects that Bank staff
will take prospective action to ensure that underlying legal obligations
mirror the disclosures provided to its customers.
By direction of the Supervisory Appeals Review Committee
of the Federal Deposit Insurance Corporation.