I am confused as I see the toll-free number to be only for mail or internet transactions. If it is not a mail or internet situation, then it appears the phone number solution for oral disclosures is not applicable.
(b)(2) Oral disclosures. The creditor also shall provide the disclosures required by paragraphs (a)(1), (a)(3) and (a)(4) of this section orally before consummation. In mail and internet transactions, the creditor satisfies this requirement if it provides a toll-free telephone number on or with the written disclosures that consumers may use to obtain oral disclosures and the creditor provides oral disclosures when the covered borrower contacts the creditor for this purpose.
Brenda W, CRCM