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Appeals of Material Supervisory Determinations: Guidelines & Decisions

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.