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Underdisclosed TIL
Answer by Dan Persfull, BOL Guru
Guru Bio

Question:  Is it true that if you have an underdisclosed TIL by more than $100 and it's only due to prepaid interest, it is not considered a violation?

Answer:  No. 226.22(a)(4)(i) The rate results from the disclosed finance charge; and(ii) (A) The disclosed finance charge would be considered accurate under 226.18(d)(1); or 226.18(d)(1)(i): is understated by no more than $100.

First published on BankersOnline.com 7/02/07









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