The Supervision Appeals Review Committee (“Committee”) of the
Federal Deposit Insurance Corporation (“FDIC”), on November 18, 1997,
considered your appeal of the violation of Section 226.4(d) of Regulation Z,
which implements the Truth in Lending Act, cited in the Compliance
Examination Report (“Report”) as of July 17, 1997.
The Committee, after a review of the material submitted with
the appeal, has concluded that the violation should be affirmed. This
decision is considered a final supervisory determination by the FDIC.
The Committee reached its determination
after due consideration of the information presented by [Bank] (“Bank”), the
material contained in the examination work papers, and a legal analysis
prepared by FDIC counsel.
The Committee notes that the
requirements for making reimbursement according to the provisions of Section
108(e) of the Truth in Lending Act have been tolled during the consideration
of this appeal. The Bank should now proceed to take the actions required
under that section to reimburse affected consumers within 60 days of receipt
of this letter.
By direction of the Supervision Appeals
Review Committee of the Federal Deposit Insurance Corporation.
