12 CFR 226.18(a) indicates that the creditor's name is one of the required disclosure items. 226.17(a) says that the disclosures must be grouped together. Our disclosures are on the bottom half of the note, but the bank's name is only stated at the top of the form. In other words, it's not in the "Fed box." Problem?

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Not a problem.

Footnote 38 to 17(a) explains that the creditor's identity may appear apart from the segregated disclosures. This is also discussed in the commentary to 17(a) as well as in the commentary to 18(a).

"Not a legal opinion and does not necessarily reflect the views of my employer"