TIL Redisclosure – Reopen ROR Period?
Randy Carey, BOL Guru Guru Bio
Question: If a TIL has to be redisclosed after funding due to material error, is it necessary to formally reopen the rescission period via a new right to cancel?
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Answer: First, redisclosing a TIL because it contains material errors does not fix the original disclosure issue. There is no regulatory basis for curing an inaccurate TIL by sending a new disclosure. The rescission period will now run for three years.
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