National Bank , a $15 billion in asset national bank located in Sopchoppy, Florida is in the lending business (this is a small to midsize bank relatively in size). Dogood has a program of helping each borrower through the lending process by requiring potential borrowers to engage in the bank's financial literacy course. The bank requires the course to help borrowers understand the documents and the loan product that they are obtaining from the bank.

In addition, Dogood decided to include extra disclosures to help explain some of the documents.However with all of the additional disclosures, some of the documents became quite long so the font size was reduced to help fit the extra disclosures. They also used a shadow box font that some people described as making it difficult to read, but others say it improved their ability to read the document.

The number of disclosures at closing often overwhelmed borrowers despite having attended the financial literacy class and the assistance by the bank. Many borrowers at the end of the loan process said that thy were overwhelmed by the information that they were provided and did not really understand what they signed but went ahead with the transaction because they just "wanted the home". The bank examiner has received a complaint from a borrower after they defaulted on their mortgage after 4 years in the home. The home was placed in foreclosure. This is the only complaint received out of 1,000 mortgage loans made by Dogood in the past 4 years. What are at least 4 practices that may be considered abusive by Doogwood? What defenses could Dogood raise against a regulator's claims of potentially abusive practices, addressing each of the alleged violations? What policies and procedures should Dogood implement to ensure borrowers understand the loan products and associated documents while maintaining compliance with regulatory guidance?