Appeals of Material Supervisory Determinations: Guidelines & Decisions
SARC-97-04 (December 4, 1997)
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.