In the Interagency Guidance Regarding Unfair or Deceptive Credit Practices that the agencies issued in August of 2014 they signaled their views on the Cosigner Notice in footnote 11, which said:
“The Agencies note that the FTC’s Credit Practices Rule requires—and the former credit practices rules applicable to banks, savings associations, and Federal credit unions required—creditors to provide a “Notice to Cosigner†explaining the cosigner’s obligations and his or her liability if the borrower fails to pay.
The Agencies believe that creditors have properly disclosed a cosigner’s liability if, prior to obligation, they continue to provide a “Notice to Cosigner.â€
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20140822a2.pdf