APR s & Early TIL Redisclosures
Answer by David Dickinson, BOL Gurus Guru Bio
Question:
When determining if an early TIL needs to be redisclosed three days prior to consummation, how do I know if the APR is within the 1/8th of 1 percent tolerance? My bank issues an early TIL at application and a final TIL at closing. The APR disclosed in the early TIL is based on the index on that day. Am I comparing the difference between the APR disclosed in the early TIL to the APR disclosed in the final TIL, or am I making sure the APR disclosed in the early TIL is accurate based on what the APR actually was on the day of application?
Answer:
You compare the APR on both the P-TIL and the Final TIL. If the final TIL is outside of tolerance, you must redisclose and wait to close.
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