Reg Z Disclosures on NonReg Z Loans

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Question:

After several years of trainging and memos, the lending department management continues to provide consumer FED BOX disclosures to applicants who qualify for the exemptions of Reg Z business, ag, corp, amounts greater than $25,000, etc. Please provide horror stories, agencyordered restitutions, court cases, etc. to help me fight this

Answer:

There's nothing wrong with TIL disclosures to exempt parties. Your only risk is that you might "give something away" via a disclosure that's not actually required by the note. If you've told the customer you'll do something (even if you didn't need to make the disclosure), you're probably stuck with honoring the disclosure.

First published on BankersOnline.com 7/1/02