FDIC Secures $300,000 Penalty from Bank for Alleged TILA Violations

On October 18, the Federal Deposit Insurance Corporation (FDIC) issued an order requiring a Kentucky bank to pay civil money penalties.  The order resolves allegations that the bank violated section 122(a) of the Truth in Lending Act (TILA), 15 U.S.C. § 1632(a), and section 1026.5(a)(1) of Regulation Z, 12 C.F.R. § 1026.5(a)(1)​ by failing to clearly and conspicuously disclose required information related to a particular line of credit product.  The order also resolves claims that the bank violated section 5 of the Federal Trade Commission Act (FTC Act), 15 U.S.C. § 45(a)(1), by using a processing order for certain deposit account transactions contrary to the orders described in the bank’s deposit account disclosures.  Pursuant to the order, the bank will pay a $300,000 civil money penalty to the FDIC.