Redisclosing the TIL
Answer by David Dickinson, BOL Gurus Guru Bio
Question:
Do we redisclose the truth in lending if the locked interest rate is lower than the rate used for the initial disclosure at application? Do we redisclose the truth in lending when going from a "to be determined" property to an actual property?
Answer:
Refer to our Blog on 9/3/09 concerning over-disclosed APRs. If the property hasn't been identified, you do not have an application for RESPA or TIL yet. No P-TIL or GFE is triggered at this time.
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