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#1055851 - 10/01/08 08:04 PM Commercial Lending Closing a Consumer Loan
TIG Offline
Junior Member
Joined: Nov 2005
Posts: 37
Southeast
Commercial Lenders in our bank are not allowed to close consumer transactions,however; one fell through the cracks.
6 Month Loan - To refi and Rehab the consumer's primary residence.
Lender failed to provide a final TIL. How do you calculate the APR violation on this one?

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Lending Compliance
#1055978 - 10/01/08 09:29 PM Re: Commercial Lending Closing a Consumer Loan TIG
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Did they provide a Preliminary TIL? If so, a final is not required if the P-TIL is accurate.
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#1056165 - 10/02/08 12:52 PM Re: Commercial Lending Closing a Consumer Loan David Dickinson
TIG Offline
Junior Member
Joined: Nov 2005
Posts: 37
Southeast
No, It was treated as an as though it was an investment property.
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#1056189 - 10/02/08 01:01 PM Re: Commercial Lending Closing a Consumer Loan TIG
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
I believe you use the actual rate then as the APR since one wasn't provided.
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