Ok, here's an obscure question....

Reg DD says:

230.3(a) Form. Depository institutions shall make the disclosures required by §§ 230.4 through 230.6 and § 230.10 of this part, as applicable, clearly and conspicuously, in writing, and in a form the consumer may keep.

Does anyone have a definition of "clear and conspicuous"?

I know I heard somewhere that 10-12 pt font would be passed without any problem, but that 8 pt was pushing it...

Can't remember where I heard that, and now that we're printing up another batch of disclosures, they want to know if we can scale it back to 8 pt to save paper (read: to save $$).

I can't find any citations for recommended sizes, and was wondering if anyone out there might be able to point me in the right direction...

I'm not aware of any guidance in this area, specifically under Reg DD, but HERE is a BOL Guru post relating to fonts and disclosures RE: Credit Card - specifically mentioning 8 point as not meeting the standard - covering that product.

Some of this is, will a reasonable person see your disclosure and be able to understand them? Is it buried in small fonts or hidden at the end of a 30 page disclosure?

If you want to use TISA disclosures to make your product understandable and marketable, you need to understand your target market. If you market to a largely "seasoned citizen" crowd, you might want to rethink that "save paper" mentality, and jack up your point size for some offerings.

Can you spell "presbyopia"?

Consider "boomer enhancement" to be a part of your ADA responsibility or just good business---I don't buy it if I can't read the small print. (Warning: extended exposure to the duties of compliance managment can result in irreversable cynicism.)

You may also want to look at state law. I belive (not certain) that NJ has a law which requires a minimum size font.

I've been told no smaller than 6 pt

Thanks for the help, everyone.

I printed out the Reg Z info (Thanks, Ten.), and let my manager know about the ADA issues, etc. (I know I have trouble reading 8 pt without assistance, and I don't need reading glasses - yet.)

We'll probably go with 10 pt font (right in the middle), just to try and apease both sides.