I can't see an objection to making the disclosures "in a personal phone call" assimilated to in-person as that will more than meet the results of a toll free call, assuming the borrower isn't paying for the call. My issue with the bank making the calls is time zones as our military customers were in Germany, Korea and the Middle East as well as hours away in the US. When you get 8 or 10 hours difference, you have to time the calls well.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell