Answer:
Yes. This was a confusing requirement because it was always contained in a law that had a sunset provision, so the requirement seemed to come and go periodically. Many banks simply followed the requirements even when they didn't exist. It didn't hurt anything and the information provided in the disclosure stayed current because HUD allowed it to. It would have cost more in programming time to turn it on and off. This requirement became permanent in 2001. You can read more on it here on BOL as well in various banking bulletins. National banks would be referred to OCC 2002-27.
First published on BankersOnline.com 7/28/08
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