However, should your institution be using old forms or software-generated forms that may not yet be updated, or if there is any question about your disclosure, we suggest you take interim steps to ensure your compliance. TILA has a 12-month statute of limitations for violations and the Act also allows creditors to correct disclosure mistakes by sending a notice within 60 days after the creditor learns of the error. Click here for a copy of a sample letter several lenders have used to notify their customers when they found their disclosures were not technically correct. Of course, you would want to discuss this issue with your bank s counsel and document your actions in your compliance files. Cases like these are always on the agenda for GBA's annual Bank Counsel Conference sponsored by the Bank Counsel Section .
Membership is the Section is available to attorneys representing banks as well as in house counsel.
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