We had a loan secured by a CD that was for the purpose of college expenses of the borrower's daughter. No PEL disclosures given. What is the best way to rectify this? Give the borrower the approval and final disclosures or just the final disclosures? I appreciate any Guru's opinion on this matter!

OK. I really need some help. I am reviewing the PEL disclosures and this is very confusing since we never disclosed in the 1s tplace. Since this loan has already been consummated and disbursed, should the right to cancel reference the dates that there was a right to cancel or does the borrower now have a right to cancel and we put in the applicable dates now?

Any Gurus out there?