Question: Do you have any advice for ways to develop new disclosures?
Answer: While it is always possible to purchase new forms from form supply companies, you usually end up with standard language which you must carefully review to be sure that the disclosure accurately describes your practices and products.
If you are developing your own forms, we strongly recommend that you begin with any model forms provided in regulations. For example, if you are developing forms for a new adjustable rate mortgage program, use the model clauses provided in Regulation Z's Appendix H. The model forms are generic and, if they accurately describe your product, you have some protection for using model forms.
What we definitely do not recommend is borrowing or copying forms from another financial institution. Not only do you risk using a form that doesn't correctly describe your product, you also risk copying someone else's mistake.
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