During my consumer loan review, I found two savings secured loans that were missing the "required deposit" disclosure in the Fed Box of the Truth in Lending [Reg. Z 226.18(r) and footnote 45]. Would we have to re-disclose the Truth in Lending to these customers, or just fix the problem going forward?

We would write it up as a violation and we would ask the loan processing department supervisor to review with the loan processors the importance of checking the proper box in the process of producing the loan documents so that this statement would appear on the loan documents; and, we would ask the lending officers' supervisor to review with the lenders the importance of doubling checking the loan documents for this verbiage before the documents are signed by the customer.